Mr. Alain J.P. Belda
390 Park Avenue
New York, NY 10022
Reykjavik 5 July, 2002
Dear Mr. Alan J.P. Belda,
Last March conservationists across the world welcomed Norsk Hydro's decision to pull out of the controversial Karahnjukar Dam Project, which is to produce energy for an aluminum smelter in Reydarfjordur. We were therefore surprised to learn that Alcoa, which places great emphasis on environmental performance in its public statements, is now in negotiations with the Icelandic government concerning this development.
The hydropower component of the Karahnjukarproject will have major impacts on the second-largest wilderness area in Europe, as it requires the construction of numerous roads, dams and tunnels in an area that currently has little infrastructure and a strong wilderness character. Given how little wilderness Europe has left, this area has considerable intrinsic value. Its protection as a national park is a matter of high priority for Icelandic nature conservation groups and they have full support from the WWF and other international conservation organizations.
Construction activities will disturb about half of 22 protected sites of special natural interest located in this area. The project will involve partial flooding of and direct impacts on 25% of a nearby protected area, Kringilsarrani.The area is protected as a reindeer calving ground. The reindeer calve on either side of Jokulsa a Bru/Dal, and then migrate to the east. The reservoir, dams and roads will create a physical barrier to reindeer migration.
Soil erosion is a very serious problem in Iceland and much of the country's original vegetation is gone. The 57 sq. km area that the Halsllon reservoir will cover, and the area to the east of the reservoir, contain some of the best and most intact examples of the original Icelandic highlands vegetation. Because this vegetation is scarce elsewhere, it has even greater conservation value. It is also an important habitat for geese and reindeer, that depend on the vegetation for feeding. Not only will the reservoir directly impact some of this vegetation, but erosion and wind borne dust from the margins of the reservoir pose a large and presently unaddressed threat to the vegetation to the east.
In this low-productivity ecosystem, the presence of water is essential for biological diversity. The highest biological diversity, including original vegetation, is found near and on the sloping banks of the three river systems running off the glacier. The project will dam and divert two of these three rivers. It is obvious that this will then change the productivity of the area, as well as the conditions of life near the original courses of the rivers, in adjoining wetlands, and in lakes. The diversion of the very muddy glacial river, Jokuls a Bru into the Lagarfljot lake and river system will seriously affect conditions for life in these waters.
Approximately 70% of the project's impacts will come from the damming and diversion of the middle river, Jokulsa á Bru/Dal. These impacts, including the formation of the 57 sq. km reservoir/dam, are an unavoidable part of the hydropower project. Flow in the 100-180 meter deep and scenic canyon below the Karahnjúkar Dam will disappear altogether except for one or two late summer months. Another 20-25% of the project impacts will come from the damming and diversion of the eastern river, Jokulsa i Fljotsdal.
Furthermore, as you are probably aware, the project was rejected by the Icelandic Planning Agency. On August 1st 2001, the Icelandic Planning Agency made a clear ruling against the Karahnjukar hydropower facility due to its enormous environmental impact. The Icelandic National Power Company, Landsvirkjun, a partner in the scheme, submitted an appeal to Iceland's environment minister, Siv Fridleifsdottir. Minister Fridleifsdottir overruled her own Planning Agency and granted permission to proceed with the project, with some minor revisions to limit the amount of environmental damage.
In Iceland, there is no dispute that the Karahnjukar Dam Project, also in its current form, will have significant, direct and lasting impacts on the most diverse and well-preserved area in the Icelandic highlands. The conditions set by the Minister of the Environment will make little difference to the scale of destruction. In addition, in her ruling, Ms Fridleifsdottir failed to provide sound arguments to support her decision, and to adequately explain what environmental impacts will result from the development.
Recently, the High Court of Iceland ruled that the Iceland Nature Conservation Association and three individuals have legal standing in order to sue Ms Siv Fridleifsdottir, provided they also sue Landsvirkjun, for overturning the previous decision by the Planning Agency. The plaintiffs have decided to proceed with their lawsuit.
Because of the project's undisputed environmental impacts, and because of the controversy it has aroused in Iceland, we urge you to withdraw from negotiations with the Icelandic government concerning delivery of energy from the Karahnjukar Dam Project for an aluminum smelter in Reydarfjoerdur.
Association for the Protection of the Highlands of East Iceland
Thorhallur Thorsteinsson, chairman (sign)
Iceland Nature Conservation Association
Arni Finnsson, chairman (sign).
Icelandic Society for the Protection of Birds
Jóhann Óli Hilmarsson, chairman (sign)
Landvernd, National Association for the Projection of the Icelandic Environment
Ólöf Guđný Valdimarsson, chairman (sign)
NAUST, Nature Conservation Association of Eastern Iceland
Helgi Hallgrimsson, vice chairman (sign)
Anna Gudrun Thorhallsdóttir, chairman (sign)
SUNN, Nature Conservation Association of Northern Iceland.
Ingólfur Á. Jóhannesson, chairman (sign)