Kultuuriministeerium 11.05.2023 nr 6-5/23/1622-3
Sisend Euroopa Komisjoni kirjale
vastamiseks: Permit extension of the
Linnamäe hydropower plant
Saadame lubatud sisendi vastamaks Euroopa Komisjoni kirjale Linnamäe hüdroelektrijaama loamenetluse
kohta. Euroopa Komisjoni kirja edastasime Kultuuriministeeriumile vastamiseks 28.04.2023 kirjaga
nr 6-5/23/1622-2.
1. Question: Has an appropriate assessment under Article 6(3) of the Habitats Directive been carried out
before the first permit decision in 2008 and if so, what were the results? If there was no assessment, please
explain why.
Answer: The first permit was issued in 2002, the next permit on 15.01.2008 by Harju County Environmental
Department. The second permit was granted to Eesti Energia as a special water use permit No L.VT.HA-
171918 in the profile of the Linnamäe dam for the production of electricity from hydropower. No EIA nor
AA has been found in this regard. Section 3.10 of the special water use permit states the justification for
granting the special water use permit, but unfourtanately related justifications cannot be found also due to
the reorganization of institutions and changing the staff. The permit states that: „Eesti Energia AS
Taastuvenergia company restored the Linnamäe HPP located at the mouth of the Jägala river in 2002. They
were issued a special water use permit HA0523 (L.VT-12822), which was valid until 15.01.2008. a. The
company applied for a special water use permit to continue producing electricity from hydropower in
connection with the expiration of the existing permit.“ The EIA was initiated to carry out also appropriate
assessment by Environmental Board in 2015 because a new water permit for hydropower production was
applied for again. The EIA was terminated in 2022 taking into account the results of
court case No 3-17-1739 of Administrative Board of the Estonian Supreme Court. After that Environmental
Board carried out the Habitats Directive Art 6.3 and Art 6.4 assessments by itself.
5. Question: Will Estonia ensure that the Article 6.4 notification will be submitted to the Commission before
the permit is issued (including compensatory measures, studied alternative solutions and imperative reasons
for overriding public interest)? Or has the permit been granted already?
Answer: New permit has not yet granted due to pending court proceedings about Governmental
order No 163 of 3 June 2022. The existing permit has been expanded until the end of 2023. Article 6.4
notification will be submitted to the Commission after the end of court proceedings.
Lugupidamisega
(allkirjastatud digitaalselt)
Marku Lamp
Asekantsler
Kadri Möller, +372 626 2876
[email protected]
Paldiski mnt 96/ Tallinn 13522/ 626 2802/
[email protected]/ www.envir.ee/
Registrikood 70001231