AS “Latvijas valsts meži” (hereinafter – LVM) has assessed the environmental impact assessment (hereinafter – EIA) report prepared by SIA “Estonian, Latvian & Lithuanian Environment” for the construction of the 330 kV Ventspils – Brocēni – Varduva/Telši (LT) power transmission line.

The EIA report states that the corridors selected for the construction of the planned 330 kV power transmission line (hereinafter – PTL) make maximum use of the existing 110 kV PTL routes. This approach was chosen after assessing technical, economic, environmental and social aspects. The chosen solution is strategically justified, as it makes it possible to:

– reduce the need to take up new land, to change the type of land use and to impose new encumbrances;

– reduce the impact on the public by avoiding the creation of new route corridors across extensive areas and thereby lessening public opposition;

– reduce the environmental impact, including the extent of deforestation, habitat fragmentation and the visual impact on the landscape;

– optimise project costs, since the use of existing routes reduces the amount of compensation payable to the owners of the affected land, facilitates the construction of infrastructure and simplifies technical connections and construction logistics, thereby making the chosen route alignment considerably more advantageous than it would be if the proposed activity were carried out entirely within a new corridor.

On reviewing the EIA report, it is evident that a number of sub-alternatives have been developed which, if implemented, would run counter to every single point of the strategic justification originally set out for the 330 kV PTL. Depending on the route alternative chosen, deforestation is envisaged over an area of 165.8–296.1 ha, changing the type of land use and imposing new encumbrances. The Kuldīga bypass project alternative crosses the Natura 2000 specially protected nature territory, the Ventas ieleja nature reserve.

LVM fully objects to taking forward sub-alternatives 5 and 8, because the creation of a new PTL corridor in areas managed by LVM will significantly affect LVM's economic activity – timber-producing areas will be reduced, deforestation will be carried out, and the restrictions imposed within protection zones will, taken together, have a significant negative impact. Instead, we ask that consideration be given to reducing the visual impact by using cable solutions on those sections of the existing route where the visual impact on the landscape is particularly significant.

At the same time, we would point out that if, as a result of the EIA, any activities are planned that affect the territory managed by LVM, written approval from LVM is required for their planning and implementation. Furthermore, if the 330 kV PTL is planned along a new route on state forest land, it cannot be implemented without a servitude and restriction agreement with LVM.

LVM greatly values projects for the development of Latvia's energy system, while at the same time minimising the impact on areas available for forest management arising from the use of state forest land for national defence, transport infrastructure and municipal industrial park functions.