1) ILLEGALITY OF THE AGREEMENT ON RUSSIAN GAS SUPPLY TO TURKEY.
The agreement, concluded in 1997, is not legal to a full extent as it is obliged to undergo the state ecological review as per art. 11.7 of the Federal Law of the Russian Federation (RF) "About the ecological review" (). Notwithstanding, the agreement did not undergo the State ecological review, in spite of obvious and serious impact of the quoted project implementation on the Black Sea ecological system.
The same very Law (art. 18.5) provides that "The failure to satisfy the requirement of the obligatory state ecological review of an international contract project entails declaring its invalidity".
So, as realization of Russia-Turkey gas pipeline project has been based upon this contract, and as it hasn't undergone the obligatory ecological review, all the subsequent decisions concerning the "Blue Stream" project are also illegal.

2) VIOLATION OF PUBLIC RIGHTS TO PARTICIPATE IN DECISION-MAKING PROCESS FOR ENVIRONMENTALLY DANGEROUS PROJECT
The obligatory public hearings procedure had not been held while Russia-Turkey gas pipeline ("Blue Stream") project was developed.
None of the actual functioning public ecological organizations, dealing with the problem, none of the local communities was engaged into public hearings on the project.

3) THE NESSESITY OF INTERNATIONAL ENVIRONMENTAL IMPACT ASSESMENT FOR THE "BLUE STREAM" PROJECT
This project carries great threat not only for the Russian part of
the Black Sea aquatory and coast, but for the ecological system of
the sea in general. Other Black Sea countries could suffer as well as a result of fulfilling the project. Due to the transboundary impacts of this project, the international environmental impact assessment of Russia-Turkey gas pipeline must be carried out before the construction of the maritime section of the project.

4) THE INADMISSABILITY OF DESTROYING THE PROTECTED NATURAL AREAS AND THE RED DATA BOOK SPECIES.
The coastal part of the gas pipeline which is being constructed by Saipem company, subdivision of ENI, was designed on the territory of the nature monument Forest of Crimean pine "Arkhipo-Osipovskoe" and this is a gross violation of the Law.
At this time the unique forest tract of the Crimean & Pityisa pine (listed in The Red Data Book of Russia) is under illegal cutting.
This monument of nature is protected as a reserve and forms part of the Russian Federation nature-reserved fund. As per the Russian law "On protection of nature" and Land Code any withdrawal of the lands belonging to the Russian Federation nature-reserved fund is inadmissible.
So, taking into consideration the supremacy of the Federal Laws over any other acts, all the decisions on withdrawing the lands for the construction of the gas pipeline within these protected area & on withdrawing Forest of pine Crimean "Arkhipo-Osipovskoe" from the nature-reserved fund of RF are absolutely illegal.
In the statement of the state ecological review of Russia-Turkey gas pipeline ("Blue stream") project ratified by the Order of the State Ecological committee of RF # 302, from May 18, 1998, the fact that the construction of gas pipeline was going to affect the protected area (nature monument "Forest of pine Crimean "Arkhipo-Osipovskoe") was not reflected.
In relation with this a problem of the review legality arises and its resolution can be disputed in court. The project should undergo grave changes concerning the gas pipeline construction and "Beregovaya" compressor station commissioning.

5) THE INADMISSABILITY OF THE GAS PIPELINE CONSTRUCTION IN THE RESORT'S SANITARY PROTECTION ZONE
The works on the maritime section construction of the gas pipeline in Russian coastal area are illegal because they were planned for the water basin which with special protected status which does not allow to build such objects as a gas pipeline there.
The water basin situated opposite the "Drovyanaya Schel" tract (width 500 metres from the coast line) forms part of the 1st zone for sanitary protection of Gelendzhik resort-city. The water basin (width 2 000 metres from the coast line) forms part of the 2nd sanitary protection zone of Gelendzhik resort-city. The sanitary protection zone of the resort Gelendzhik was ratified by the decision of the Council of Ministers of the RF # 484, from 17.12.1987.

The the maritime section construction of Russia-Turkey gas pipeline will be held by Italian company ENI together with it's daughter-company SAIPEM. So, moral & other responsibility for violating the ecological legislation is not only upon "Gazprom" but also upon ENI.

The International Socio-Ecological Union protests the barbarian felling of the unique forest tract on the territory of "Forest of pine Crimean "Arkhipo-Osipovskoe" nature monument and all other violations of the ecological legislation mentioned above.
The International Socio-Ecological Union calls the top management of ENI and Gazprom to a constructive dialogue with ecological community in order to find a suitable solution to Russia-Turkey gas pipeline project problems.
The International Socio-Ecological Union considers changing the location of the gas pipeline maritime section to be the solution of the problem. It should be changed so, as not to affect the sanitary protection zone of the federal resort Gelendzhik and the nature monument "Forest of pine Crimean "Arkhipo-Osipovskoe".
The International Socio-Ecological Union in view of the listed above circumstances, demands an immediate stop for "Blue Stream" pipeline maritime section construction within the boundaries of Russian economic area. The construction should be postponed until the problems connected with the violation of the law on the stage of project's designing & realization are solved.

Co-chairmen of the Council of the International Socio-ecological Union

Zabelin S. I.
Ziganshin I.I.
Kayumov A. A.
Krichevsky S. V.
Rybakov D. S.
Fedorov L. A.

September 19, 2001

INDEPENDENT SCIENTISTS CONSIDER THE GAS PIPELINE PROJECT RUSSIA-TURKEY ("BLUE STREAM") EXTREMELY DANGEROUS FOR THE BLACK SEA

Since the decision on gas pipeline Russia-Turkey ("Blue Stream") construction was taken it was not only environmentalist community to get worried about its realisation plans. Many independent scientists on the basis of information available to them expressed their concern about the fact that this project could cause irredeemable damage to the Black Sea ecological system.
In particular, in order to make an independent environmental impact assessment of the project a group of independent experts was formed within Black Sea Socio-Ecological Centre, Gelendzhik. (There is a point not far from this town where the gas pipeline will enter the Black Sea basin). As a result of study of the pipeline impact's various aspects an analytic information on maritime and coastal Russia-Turkey pipeline areas was prepared by the expert group. The scientists indicated the dangerous factors of the gas pipeline construction and made their recommendations on how to lessen the dangerous impact of the gas pipeline.
This information was forwarded to various State authorities of Russia related with the project.
Unfortunately, the scientists opinion was ignored.
Nothing has been changed in the project notwithstanding recommendations of the scientists. Below find enclosed the information from Gelendzhik scientists.
Currently the expert group of the Black Sea Socio-Ecological Centre is preparing an updated information, which will include new data on "Blue Stream" received by them.

============================================

INFORMATION
on the maritime and costal sections of the gas pipeline Russia-Turkey ("Blue Stream")

The authors in the present document mainly aimed at justifying their concerns about probable negative and disastrous effects produced by the construction and operation of a unique (from technical point of view) and prejudicial pipeline (see page 60 of "Decision of the state environmental assessment on the feasibility study of the Russian - Turkey pipeline construction (its maritime version) in the unique natural conditions of the Black Sea, all the undercurrent water sheets of which (at a depth of more than 100-200m) contain fatal concentration of hydrogen sulphide.
It would be fondly to believe, that today's knowledge allows to describe in details the natural and anthropogenic factors entailing a risk of disastrous effects on the environment as a result of their reciprocal action together with the gas pipeline factor. This unreliability of scientific knowledge in combination with world significance and uniqueness of the Black Sea and technical uniqueness of the designed facility constitute an obvious and unpredictable (as to its scales) risk of the Blue Stream pipeline wreck in its maritime version for all the Black Sea countries and coastal population.

I. MARITIME SECTION

1. Pipeline location
1.1. The maritime section of the gasline starts from the Drovyanaya Schel tract 5 kms to the Southeast from the resort settlement of Arkhipo-Osipovka and about 2 kms to the Northwest from the resort of Inal. The other pipeline end reaches the city of Samsun (Turkey).
1.2. Pipeline length is 396 kms long. About 11 kms of them will be laid on the Russian shelf (at a depth of about 100m),50 or 60 kms will be situated on continental slope (at a depth of from 100 to 2000 m). Further up to the foot of the Turkish continental slope, it will cross the Black Sea abyssal plain at depths of up about 2115 m. The length of the line designed to be built on the Turkish continental slope and shelf will be about 120 kms long.
1.3. A large part of the gasline will be located in international waters. Except the Russian and Turkish gasline parts
12-mile long all in all, the international portion will make 340km or 87 % of the whole maritime section.

2. Gas pipeline and its maritime section technical characteristics.
2.1. Project efficiency is 16 billion cubic meters a year or 43,8 million cubic meters per 24 hours.
2.2. Upstream pressure of the maritime section pipeline (at the compressor plant (hereinafter - CP) "Beregovaya") will be 25 MPascal (250at). Downstream pressure (CP "Samsun") will make 5,4 MPascal (54 at). Pressure drop in the pipe is expected to be about 0,05 MPascal (0,5 at) per kilometer. Upstream pressure (CP "Beregovaya") in force-major augmented mode will constitute 35 MPascal (350 at). Upstream gas temperature is +57?C, downstream one is +1?C.
2.3. The project supposes two versions of pipeline location as follows:
- 1 pipe branch with inner diameter of 700mm;
- 2 pipe branches with inner diameter of 534 mms.
2.4. Longitudinal welded pipes of steel APT-5 X70 with trizonal polymer hydraulic seal 500 microns thick (0.5 mms). Anodic protection is envisaged. Underwater work practice in the Black Sea showed, that alloy steel articles are also subject to corrosive attack of dissolved hydrogen sulphide.
2.5. Today's world practice of deep water gaslines construction does not know depths more than 1600 m. A record example is gas pipeline built at a depth of 101km on ocean bed with customized natural settings in Mexican bay outside the zone of hydrosulphuric contamination.
2.6. It is necessary to underline a circumstance missed by many project participants (and kept secret by the authors of the project), that at the first 80-90 kms of the pipe line, gas pressure will exceed the external hydrostatic pressure. Internal pressure exceeding on the edge of the shelf will make about 23 MPascal (230 at), at a depth of 1000 m (16 kms from the coast) it will be 14 MPascal (140 at) and at the foot of the continental slope (about 50 km from the coast) it will make 2 MPascal (20 at). The same situation is on the Turkish continental slope section and shelf of about 100 kms long in sum. However overpressures inside the pipe there do not exceed 5 MPascal (50 at).

3. Geologic characteristics of the pipe route and probable impact on the gasline. The Black Sea bed along the gasline route is characterized by polysurface, steep gradients (about 18œ) and is composed by nonsteady geologic formations. It is explained by recent neotectonic processes saturated with energy on the Black Sea shelf and continental slope in its Caucasian part.
3.1. There we can see an intensive accumulation of new recently formed silts. Their drop occurs partially by system of active underwater canyons, partially at slow creeping of large mass of nonlithified silts, and also at activation of underwater landslides transforming into mud and rock or mud flows (see page 67-68 of "Decision of the state environmental assessment"). Great density and speed of these flows causes their large energy sufficient for destruction even of high-strength heavy wall pipes of the gasline.
3.2. Neotectonic motions of the earth's crust near the Caucasian continental slope generate here seismic earthquake centers of 8-10 balls in focus, that is just enough for destruction of the gasline. However even weak seismic fluctuations (their recurrence rate is much higher) are able to initiate the mentioned above geological processes. Seismic risk as to the Turkish shelf and slope is confirmed by recent seismic events in Turkey.
3.3. In case of affection of the pipe line by small-scale or peripheral parts of water-ground flows, thin (0,5 mm) hydraulic seal of pipes will be most probably destroyed; what ( in conditions of a high corrosivity rate of hydrosulphuric Black Sea water (9-14 mg/l) will promptly lead to destruction of the pipe line walls.
Besides that such flows are able to create vast holes under the pipe line or to bridge it over by the ground dropped out of a flow.
3.4. Within the territory of the Caucasian continental slope and its foot diaper folding has been found (often expressed in bottom relief); as well as indications of intensive gas and hydrate saturation of bottom sediments and mud volcanism (see page 67-68 of "Decision of the of state environmental assessment"). Thermal and mechanical effects of the pipe line can result in change of strength properties of bottom sediments, what will initiate mechanical pressure inside the pipe line walls, increasing risk of its destruction.
3.5. Different opinions of experts as to scales and recurrence of the above mentioned geologic phenomena are lawful. However the existence of these phenomena is confirmed by numerous observations. In particular, the hydrographic service of the Black Sea Navy has captured powerful underwater moving of grounds in the area of Idokopas Cape (approximately 30 kms north-west from the beginning of the gasline maritime section); they were noticed due to breakaway of an underwater cable and formation of tsunami-like waves registered by specialists.

4. Gas breakthrough (script of a catastrophe).
In item 2.6 it have already been mentioned, that contrary to the protestations of the authors, owners and supporters of the project "Blue stream" that on the Black Sea bed the gas breakthrough is not possible, almost 170 km of the pipe line will be under considerable exceeding internal pressure. But, both the sections, Turkish and in particular Russian ones are designed within the limits of complex from the geological point of view and consequently risky parts of the route (see p.3). However the destruction of the pipe line can be provoked not only by natural processes, but also by wars, military exercises, acts of terrorism, breach of the gasket technology and the gas pipeline operation and maintenance, as well as accidental impact as a result of various activities in the water area.
4.1. Gas breakthrough out of the pipe laid on the shelf will lead to the emission of tens millions cubic meters (according to tentative estimations it will be more than 50 million cubic meters) of compressed gas into water mass, and then into the atmosphere . The spontaneous combustion of gas is very probable due to electrostatic effects in a cloud of spray above the emission center. The combustion of gas can have an explosive character. The high probability of this is confirmed by numerous cases of spontaneous combustion and detonations of gas at eruption of mud volcanoes (including underwater ones) in Azerbaidzhan, on Kerch and Taman peninsulas. Lifting and intermixing of water strata by gas will take away from the sea bottom friable silty precipitation. The scales of water contamination then are comparable to consequences of a strong gale. It is admitted even by the developers of the project. However, they do not take into account the fact, that the storm contamination of sea water is localized in a coastal area and width of contamination strip seldom exceeds 0,5-0,7 km. The width of the shelf (see item 1.1) in the pipeline construction strip makes 11 km, and the sea here is habitable down to a depth of more than 100 m, while the biota is not adapted to powerful mud loads.
4.2. Destruction of the pipe line and gas breakthrough on the continental slope are possible for the reasons, indicated in item 3, on all its extent up to the point, where internal pressure in the gasline is equal to the external hydrostatic pressure (see item 2.6). At gas breakthrough at a depth of 1000 m (approximately 15 km from the shore), where the overpressure inside the pipe is of 14 MPascal (140 at) more than 30 mln cubic meters of gas will be thrown out into water strata, and then into the atmosphere.
Reaching the sea surface, gas will carry away due to air-lift effect about 600 thousand cubic meters of water, contaminated with hydrogen sulphide (H2S concentration - 9-14 mg/l). One part of hydrogen sulphide will be degased into the atmosphere, and another part will destroy all the biota in the inhabited 200-m layer around the catastrophe center. Together with water, huge quantities of bottom silty precipitation also containing hydrogen sulphide will be raised up. A spontaneous combustion of mixed gas and explosive processes at gas burst into atmosphere are very mach likely to take place in the same way as at gas breakthrough on the shelf.
4.3. Geologic characteristics of the Turkish shelf and continental slope and also the overpressure inside the pipe, beginning with 290th km of the pipeline route, reaching here 5 Mpascal, all that makes possible the destruction of the pipe and gas burst on this part of the "Blue Stream" as well. 4.4. The destruction of the pipe line within the Black Sea abyssal plain (approximately from 90 up to 290 km of the route) can take place as a result of mud volcano activity, softening and fluctuations of base grounds because of their degasification and decomposition of gas hydrates, which can be contained in base grounds. However only on this portion of the route gas burst into water strata is not possible due to the exuberant external pressure of water. In this case even at small disturbance of air- tightness, the pipe will be supplied with water at a pressure of about 8 Mpascal (80 ATM).
Near-bottom thermobaric conditions and large amounts of compressed gas are congenial for generation of powerful gas- hydrate plugs inside the pipe.
The presence of hydrogen sulphide in the water can play the role of catalyst in this process, despite the inhibiting effect of water salinity. The removal of stypage of the pipe line by gas hydrates is a rather complicated problem, it is technically possible only at a large distance from the pipeline entry.
4.5. In case of mass gas breakthrough (see item 4.1.-4.3.) the character of the Black Sea streams will promote carrying out of raised hydrogen-sulphide water and suspended matters toward the Russian resort coast and further to Crimea (Ukraine). In case of breakthrough in the Turkish part of the sea besides the Turkish coast the Georgia one can suffer.
The meteorological conditions during catastrophe period can aggravate its consequences because of windward flood towards the populated coastal strip of hydrogen sulphide, ingressed into the atmosphere above the center of breakthrough or inflammable methane and products of its combustion, if it would be breakthrough on the shelf (see item 4.1. and 4.2.) Besides that, effects of gas breakthroughs outside the pipe described in items 4.1. and 4.2. are dangerous for navigation, specially for passenger and tourist routes, located from 10 up to 50 km from the coast. The character of development and scales of negative and disastrous consequences of gas breakthrough outside the pipe on the Black Sea bed can be much more various and intensive, than the above mentioned examples. The necessity of a more detailed research assessment of consequences of damage and destruction of the pipe line on the sea bed is recognized by experts (see page 92 of "Decision of the state environmental assessment").
5. International legal and political aspects of the Blue Stream project (maritime version).
5.1. Russia, being historically a Black Sea state, participates in international conventions and agreements on environmental safety of the water areas and whole basin of the Black Sea. In Bucharest, in 1972 Russia actively participated in the development of the Convention of 6 Black Sea countries on the Black Sea protection from pollution and signed it. The Black Sea Environmental Program (BSEP) is set up and works with the participation of Russia. This organization elaborated important documents and made them signed by the ministers of nature protection departments of six Black Sea countries. Among them "Black Sea Transboundary Diagnostic Analysis" and "Strategic action plan on the Black Sea rehabilitation and protection". In these documents is underlined the transboundary character of environmental processes and risks concerned with them in exclusively self-contained Black Sea basin, in which practically any environmental negative accident, process or risk of such incidents affect the interests of all Black Sea countries and their population. The above mentioned data shows a high degree of probability of negative and disastrous environmental effects of the Black Sea gas pipeline "Blue Stream", that can affect the concerns not only of the countries - participants of the project, but also of the whole Black Sea region. In this connection it is clear, that the narrow branch-wise approach to the design and implementation of the project "Blue Stream" by Gazprom's leadership contradicts not only international obligations of Russia, but also its long- term geopolitical interests.
5.2. It is known, that alternative versions of Russian gas deliveries to Turkey were also under discussion. The "Eastern" version envisaged gas pipeline construction through the territory of Georgia and (or) Armenia. The "Western" one required the extension of already existing pipe line system through the territories of Ukraine, Moldova, Romania and Bulgaria with an output to the European part of Turkey. Both versions, unlike the marine one, are feasible with the help of traditional, tested and reliable technologies. Both versions, apart from adjustment of acceptable economic relations with Turkey, would provide long-term strengthening of Russia's positions in the countries bordering Russia. This obvious circumstance has not been taken into consideration in the Blue Stream project (maritime version) by Gazprom.
5.3. Already now this project, as well as its future implementation and further maintenance and operation of the gas pipeline under the Black Sea (however, like other technocratic projects of a similar kind) causes damage and will damage the Black Sea region, the only subtropical one in Russia with its unique resorts, the population of which is directly or indirectly concerned with resort activity. This damage is connected not only with loss of attractiveness of resort region containing (even in prospects) such a dangerous object. The interest in investments in resort business is in decrease, as the "industrialization" of the Black Sea coast of Russia (Blue Stream project will also promote it) increases the risk of investment into easily vulnerable resort business. The oil spill at the terminal Sheskharis (Novorossiysk) in 1997, that practically broke the resort season of 1997 in Kabardinka and Gelendzhik, serves as an example. We do not know valid legal documents corroborating and guaranteeing the keeping of promises declared by the "Blue Stream" supporters as to compensations to the resort region and its population of losses and risk related to the implementation of the project and operation of the gasline, including emergencies, as well as those concerning the gasification of the coastal settlements.

II. COASTAL SECTION

The coastal section of the designed gas pipeline crosses the territory of the resort city of Gelendzhik. Whereas the feasibility study of the Russian - Turkey gas pipeline was not considered at the local level, the Gelendzhik public organization "Public Environmental assessment" was refused to organize an assessment of the indicated seaside section of the route. However, the State environmental assessment in the decision of 23.04.1998 (issue 5.7.1) has paid a special attention to the uniqueness of forests of Mediterranean type in that part of the Black Sea coast, and to the presence of valuable flora including endemic and relict species entered the Russian Red Data Book. On page 106-107 of the State environmental assessment the choice of the route is recognized as an optimal one, bypassing the protected areas, water- protection zones and most endangered natural complexes. But, unfortunately, it is not true. It is necessary to pay attention that at the stage of route selection and at working out of the feasibility study of the gas pipeline, a seaside section is planned to be constructed on a territory having the protected area status, namely:

1. The whole area of sanitary protection district of Gelendzhik health resorts group, crossed by the gas pipeline seaside section, has the protected area status of Federal level (Ordinance of Government of Russian Federation # 591-P of 12.04.96).
2. The gas pipeline route crosses the Southeast part of the natural monument Forest tract of a pine Crimean "Arkhipo-Osipovskoe", which is under protection by the Resolution of Krasnodar Territory Executive Committee # 488 of 14.02.83. It also includes Drovyanaya Schel, a narrow seaside canyon, in which one the environment, including the Red Data Book vegetation was kept untouched due to its inaccessibility and steep relief.
3. A coastal strip of not less than 100 m wide and a contiguous water area, strip of 2000 m wide all in all, are the part of a zone of stringent sanitary protection (1-st zone of sanitary protection). The transition from the overland section of the gas pipeline to the maritime one (the threat of which has been already described) is planned to be located here.
This point, Drovyanaya Schel, is 5 km from the Arkhipo-Osipovka health resort and 2 km from the health resort of Inal (Tuapse district). The seven-km section of the coastal area, which is the territory of the above mentioned Forest tract of a pine Crimean Arkhipo-Osipovskoe, forms the special microclimate of the indicated health resorts and makes their recreational zone.
4. Considering the dimensions of sanitary - protected zones of the designed project and accompanying facilities (from 500 up to 1800 m) a considerable proportion of this unique seaside landscape will be eliminated from recreational use of health resorts. The state environmental assessment (page 116) made a well-founded remark, that the above mentioned protected areas are not taken into account in the feasibility study. So the statement that the construction and operation of the gas pipeline will not affect protected areas are wrongful. In the same item 1 the state environmental assessment notes, that the construction of the CP "Beregovaya" and the seaside section of the gas pipeline contradicts the Law of Krasnodar Territory "On natural resources, health-improving areas and health resorts of Krasnodar Territory".
It is necessary to add, that the Law of Russian Federation #26-F of 23.02.95 "On natural medical resources, health-improving areas and health resorts" is also infringed.

CONCLUSIONS AND SUGGESTIONS

The analysis of publications related to the Blue Stream project provokes the impression, that Gazprom avoids clear and detailed answers as to maritime and seaside sections of the gas pipeline.
On the one hand, Gazprom has not had any experience of construction of maritime gas pipelines. On the other hand, the conditions for the gas pipeline construction under the Black Sea are very hard, and in many respects they are extreme. Gazprom's experts seem to have more questions as to the maritime section, than answers. For this reason earnest attitude towards general public's opinions, concerns and suggestions, including environmental public together with independent experts is so important.
Our suggestions, based on the above-stated, are as follows:

1. Taking into account high risk of damaging to the environment by the construction and operation of the Black Sea Russian
- Turkey deep water gas pipeline ("Blue Stream"), and also the transboundary character of damage, specially in case of disaster, affecting concerns of all Black Sea countries,
- also taking into account, that more than 340 km of the pipe line, what makes more than 87 % of the whole pipeline route, are located in international waters,
- respecting and reckoning with the international obligations of Russia in the field of environmental protection, including prevention of damage to the environment of the Black Sea basin,
TO SUBMIT the project of international Black Sea gas pipeline "Blue Stream" (maritime section) for consideration by international environmental assessment, held by independent experts and representatives of all the Black Sea countries, including representatives of environmental public of these countries.

2. Taking into account all the long-term strategic geopolitical interests of Russia TO RETURN to consideration of other versions of deliveries of the Russian gas to Turkey, apart from the marine one.

3. TO STOP all construction and preparative works on the gas pipeline route, in the zone of the PC "Beregovaya" and maritime section of the gas pipeline, until detailed researches of underwater gasline route along all its length are completed, eliminating all ambiguous questions, related to environmental safety at the construction and operation of the gas pipeline.
To realize these researches it would be quite wise to engage marine geologic organizations based in Gelendzhik, having a rich long-term experience of sea bed research.
The population and general public should have an easy access to the outcomes of these researches, as it is put in the Law of Russian Federation "On environmental protection" 1991. The researches undertaken before on the gas pipeline route should also be obtainable and open for general public and population. These researches should be paid by Gazprom.

4. According to the Legislation TO PREPARE and TO PUBLISH, for general public be aware of them, legal contractual documents (if any others are not stipulated by the Law) on compensation for the Black Sea resort region of Russia and its population of ALL losses, damages and risks, which can occur by the reason of the designing, construction and operation of the gas pipeline "Blue Stream".
The authors of the present document believe, that the set up above information, arguments and suggestions will be a reason for serious estimation of probable negative and/or disastrous consequences of construction and operation of a technically unique gas pipeline in risky and unique natural conditions of the Black Sea and its Russian subtropical resort coast.
Great volumes of water contaminated with hydrogen sulphide (about half a million cubic kilometers) potentially are dangerous not only for the Black Sea region, but also on a global scale. The rather thin inhabited layer (100-200 m), above a dead 1,5-2km deep water strata, can be destroyed by processes initiated by a breakthrough of compressed gas out off the pipe line.
Disastrous, unpredictable as to their scales consequences are difficult to evaluate.
Today's knowledge about the Black Sea does not allow to eliminate the possibility of a similar catastrophe. As the world experience shows, the reasons of environmental catastrophes are rarely anticipated.
In already quoted "Decision of the state environmental assessment" (page 60) the experts note, that "explosive and fire threatening risk of all stages of gas transportation, large volumes of freight turn-over, extreme vulnerability of a large part of elements of the pipeline system in case of technological and natural emergencies, as well as deliberate damages (armed conflicts, acts of terrorism etc.) can cause considerable damage to the population and environment".
The significance of this quite true general statement is aggravated as for the maritime section of the gas pipeline by apparent insufficiency of our knowledge about unique properties of the Black Sea and processes on its bed and in water hydrosulphuric strata. It is unpredictability of consequences following the Blue Stream realization, that represents the main threat of the project to all the Black Sea, countries and peoples living on its seaside.
The present information is taken from the sources as follows:
- the "Decision of an experts commission of state environmental assessment on the feasibility study of the Russian - Turkey gas pipeline construction (maritime version)" of April 20, 1998.
Approved by the ordinance of State committee of Russian Federation on environmental protection. Moscow, May 18, 1998 # 302. Published in the "Environmental assessment and EIA" # 4, 1998.
- open geologic reports of past years on the Black Sea, to which we have had access, from the funds of "Juzhmorgeology" and the book "Tectonics of cainozoic sediments of the Black Sea hollow" 1985.
- numerous publications related to the project "Blue Stream", that are at the disposal of the Gelendzhik Black Sea Socio - ecological center (BSSEC)
- publications on international environmental activities in the Black Sea region.

The experts - members of initiative group of regional Black Sea Socio-ecological Center:
V.V. Solovyov - geologist - geophysicist, veteran of Research
Ocean Geophysics Institute;
V.A. Chalenko - Director of Research Manufacturing Entreprise "Juzhmorgeo Eco"
N.V.Mamaeva - doctor of biological science, veteran of Institute of oceanology of Russian Academy of Sciences;
M.M.Osicheva - architect, President of Black Sea Socio-ecological Center.
Consultations provided by the doctor of engineering science G.A.Golovko November 9, 1999

NOTIFICATION ON PROTEST ACTION

On September, 20, 2001 we, on our own behalf and on behalf of public organizations, the participants of which we are (Socio- Ecological Union of Western Caucasus, "Autonomous Action" and the "Rainbow Keepers" Movements), start a radical protest action against the construction of gas pipeline Russia-Turkey "Blue Stream" in the water area of the tract Drovyanaya Schel. The action lies in blocking the construction work on sea part of gas pipeline in coastal offshore waters.
Our decision to make a protest action was caused by great hazard, posed by sea part of the gas pipeline for ecosystem of the Black Sea and people of the Black Sea countries.
Gazprom and Italian company ENI, which are responsible for the erection of sea part of the gas pipeline, did not make objective ecological project appraisal, did not take into account the public requirements and trans-border character of the project's effect and proceed purely from their own economic interests. Thus they create the hazard of global ecological catastrophe in the Black Sea. And we could not keep from emphasizing our attitude to the fact that yesterday here, in Drovyanay Schel, underwater pipe fitting was commenced. Here and now the crime is being committed in the face of humanity, and bomb is being put under the Black Sea.
Besides, an unpecedented violation of Russian legislation on the part of Italian company "Saipem", Russian company "Gazprom" and State authorities of Russian Federation and Kranodarskiy territory took place. Due to their actions since July, 2001 in ther basin with a special protection status, offshore Russia-Turkey pipeline construction works have been commenced. It is a clear example of illegality "within the law". Unfortunately this practice is becoming more and more widespread in Russia. Whenever authorities of Russia and corporations are stongly interested in something, they do it without regard to anything. Particularity of this case lies in the fact that the environmental norms of a country foreign to them are being unscrupulously violated by the Italian company ENI represented by its branch - Saipem.
The basin, where the construction is held, with 500 width off the coast is in the first sanitary protection zone of the federal resort Gelendzhik, and 2000 meters width - in its 2nd sanitary protection zone. The sanitary protection zone of Gelendzhik resort was established as per Enactment #484 of the Council of Ministers of the Russia, as of 17.12.1987.
As per the Law of Russian Federation "On natural medical resources, health-improving areas and health resorts" (article.16): On the territory of the first zone all residence and all types of prduction activities are prohibited, with an exception for works, related with research and utilization of natural medical resources for medicine and health improvement under condition of applying ecologically pure and rational technologies.
On the territory of the second zone placement of facilities and objects not related directly with establishment and devlopment of medical resort and recreation area is prohibited as well as works polluting the environment and natural medical resources that lead to their devastation.
Notwithstanding the provisions of this law, decisively prohibiting a gas pipeline construction in this basin, these works are being carried out. Public ecological organizations more than once appealed to various State authorities and to Gazprom management in relation with illegality of the offhore pipeline construction works in the basin of Drovyanaya Schel tract. However, neither of the State authorities responsible for the maintenance of environment and compliance with the legislation, did not react to those appeals in a due manner.
Gas pipeline construction in the basin is carried out on the basis of Conclusion of the State Ecological Review for pipeline project (approved by the Order # 302 as of 18 May, 1998 of the State Committee for Ecology of RF) and Conclusion of the State Ecological Review for working project of the offshore pipeline, approved by the Order #178 as of 31 May, 2001, of the Committee for Natural Resources of Krasnodarskiy territory.
These conclusions are not legal documents, as they do not reflect the fact that the offshore Russia-Turkey pipeline construction is planned on the coastal territory that has a special protection status. In relation with this, positive conclusions of the review, permitting the pipeline construction, contradict the Law of RF "On natural medical resources, health-improving areas and health resorts" (art.16). And in accordance with superiority of the federal legislation over the normative Acts, these conclusions have to be cancelled.
Taking this action, we do not transgress the Law and we, as Russian citizens, execute our constitutional responsibility of protecting the environment. We defend our right for healthy environment and stop this harsh violation of the Law.
Current Enactment #4 as of 7 July, 1983, of the Supreme Court of the USSR "On Court Practice in Execution of the Legislation on Environment" provides the following:
16. Courts have to consider the fact that the actions of citizens, executing their social responsibilities on protection of the environment, are legal and not sunject to criminal or other penalty, even if they are forced to cause damage to the violator, as in accordance with the legislation such actions have to be viewed as necessary defence.
However, we are aware, that the Russian State repressive machine, most likely, will not consider these circumstances and that it will seek to punish us to a maximum degree. In relation with this we declare, that this action is our own initiative and that the organizations in which we participate are not responsible for it in any manner.
Taking this action we risk our lives and health. It is our conscious choice and we are fully aware of our responsibility.
Radical form of our protest is our response to atrocius disdain towards environmental issues and the destiny of the Black Sea on the part of Russian authorities and ENI and Gazprom companies.
While "normal" ways of that problem's solution, with economic interests of Russian authorities in realization of this project in view, do not bring any results, we don't see any other way to stop this illegality "within the law".

OUR DEMANDS

We demand:
- to stop the offshore works of Russia-Turkey pipeline ("Blue Stream") in the basin, having the special protection status and making part of the 1st and 2nd zones of the federal sanitary resort Gelendzhik.
- to recognize the Conclusions of the State ecological review, permitting offshore works of Russia-Turkey pipeline invalid.
- to organize an objective ecological review of the offshore pipeline project with engagement of community representatives and international experts

Yu.Tertichny (Socio-ecological Union of Western Caucasus)
R.Levchenko (Socio-ecological Union of Western Caucasus)
N.Yakovleva ("Autonomous Action" Movement)
A.Shlyonov ("Rainbow Keepers" Movement)

20.09.2001
(Inf. Independent Environmental Service on Northern Caucasus)

<September 21, 2001>

PROTEST ACTION ON CASTORO OTTO SHIP
(Greens "celebrate" start of Blue Stream marine part construction)

On September 20 in a bay connected to Drovyanaya Schel tract
there an action against construction of Blue Stream pipeline
(Russia-Turkey) took place. The action was to underline the extreme
danger of the marine part of the pipeline's construction.
The activists send a notification about the action to Saipem
company and borderguards, in which they demanded:
- to stop the illegal construction in waters of the 1st and 2nd
sanitary-protection zone of Gelendzhik resort-city;
- to accept the Conclusions of State Environmental expertise
which states that the construction of the marine part of the
pipeline is illegal;
- to organise an Environmental Impact Assessment using
international experts and representatives from environmental NGOs.
4 activists from Socio-Ecological Union of Western Caucasus,
Autonomous Action movement and Rainbow Keepers movement have
blocked pipe placing ship Castoro Otto, which started placing pipes
for Blue Stream pipeline on September 18. The boat, which came to
the bay about 10 days ago, belongs to Italian company Saipem,
however it s host-port is Monrovia (a capital of Liberia) and it
goes under Liberian flag.
At the dawn, at 6 AM, activists Yury Tertichny, Roman Levchenko,
Natalia Yakovleva and Artem Shlenov started to swim to the ship,
which was located in about 600-700 meters from the shore. Every
activist carried on his back a package with food and spare clothes
because they were going to hold a blockade for a few days. Strong
wind forced one of the activists, Roman Levchenko, to turn back, to
the shore, where he was arrested by borderguards. The rest made it
to the boat, where the work has already started and the workers
spotted them. Nonetheless, the activists managed to lock themselves
to gangways right on the middle of working area, using chains and
locks.
The spot for pipes releasing contented of two gangways going
from the boat to the sea and a pipe hanged between the gangways
with a net under the pipe. Behind these, at the deck was a place
for welding the pipes before placing them to the sea.
Natalia Yakovlava staid locked all the time, Artem Shlenov and
Yury Tertichny have chosen another tactics: they were locking and
unlocking themselves, moving on the gangways, the pipe and the net.
They managed to place a big banner No Blue Stream! . The activists
were shouting "Saipem go home!", "Ya basta!", "Saipem killed Black
Sea!" etc. Foreign workers tried to stop the activists, but
succeeded only when a reinforcement of Russian borderguards
arrived. First Natalia was arrested: the chains she used to lock
herself with, were cut using a huge cutters. Then 6 men managed to
tear away Artem from the net. The biggest problem was to arrest
Yury he escaped form the workers and climbed up, but in some time
he was arrested as well. The blockade lasted for 1.5 hours.
The activists were transported to the shore and than, together
with arrested earlier Roman Levchenko, transported to Archipo-
Osipovsky border patrol station. There they were hold all day,
however the borderguards did not placed them to a cell, but left in
a room. Some of the borderguards expressed their solidarity with
the activists, and one of them said, that he realised the danger of
the Blue Stream , but the borderguards could not discuss government
s decisions.
It took a day to decide what to do with the activists. Initially
the borderguards intended to incriminate them illegal border
crossing (in Russia it can be prosecuted by up to 2 years in
prison). However the attention of media and NGOs to the problem and
to the arrest of activists, it was decided not to complicate life
of the border patrol station and guys were released without
pressing charges on them.
It was a wise decision, since a criminal investigation would
work against borderguards and the Blue Stream project. The
construction of the pipeline in this place is illegal since these
waters are part of the 1st and 2nd sanitary-protection zone of
Gelendzhik health resort, where the Law does not allow such
construction.
The contradiction of the situation is, that the activists in
this action were protecting the Law, and they stated it in their
notification of the action, and this mean, they did not do any
crime.