Questionable Legitimacy
The Mochovce NPP project received approval by the communist regime back in 1986, without independent evaluation, public participation or even a proper Environmental Impact Assessment (EIA) process. As the original construction permit is still considered valid by the Slovak government, it initially argued no EIA had to been carried out when the project was restarted. Only after heavy pressure from Greenpeace, Slovak, Austrian and Hungarian NGOs and citizens, the Austrian government and the European Commission did the Slovak government decide in Summer 2008 that an EIA would be necessary. This procedure will not take place before construction, however, but has to be finished before the operation permit is to be issued. Construction physically strarted during the public participation procedure of the EIA. This is in breach with the Slovak law, the EU EIA Directive and the Aarhus Convention.

Manipulated Environmental Impact Assessment procedure
In the preparation of the public participation phase in the EIA procedure, SE tried to manipulated the public hearings. This became clear from a power point presentation prepared by Mochovce SE spokes person Robert Holy for the Slovak Ministry of Environment, which by coincidence was forwarded to Hungarian mayors and NGOs.

There was no public hearing in the neighbourhood of the nuclear power plant, but only in the Slovak capital Bratislava. Under the Espoo Convention also hearings were organised in Vienna (Ausrtria) and Ezstergom (Hungary). During the hearings in Bratislava a large panel of 'experts' consumed much of the time with explanations, reducing the time and energy of for participants to present submissions.

In the reactions of the project promoter on the 99 submissions of Greenpeace International, 90% of the promoter's reactions were either diverting from the issue raised or dismissive without arguments.

At the moment of writing, the Slovak Ministry of Environment is evaluating the outcomes fo the Environmental Impact Assessment and preparing its final approval.

Economic sense
Mochovce is not the least-cost option for Slovakia. Energy savings programs and available alternative energy projects could meet Slovakia's energy needs at a lower cost. The Slovak state has provided ENEL with financial support, including state aid that is most likely illegal under EU legislation (see Greenpeace briefing).

Low Nuclear Safety
Units 3 & 4 of Mochovce, by virtue of their design which dates back to the 1970s, qualify among the most outdated NPP projects in Europe at present. The outdated Soviet technologies on which it relies are missing crucial safety systems according to modern standards. The advanced stage of construction allows only limited modifications and improvements ('retrofitting') to the nuclear safety of the plant.

While current reactor designs feature double containment structures (robust walls of concrete and steel against leakage of radioactivity in case of heavy accidents, and for protection of the reactor against external events such as an airplane crash), Mochovce 3&4 has none. In addition, vulnerability to seismic activity is a weakness in the safety design of VVER 440/213 units. It is not clear whether Mochovce 3 and 4 complies with the latest seismic design standards of the International Atomic Energy Agency (IAEA).

Preventing climate protection
Slovakia is a classical example where nuclear power is preventing the development of clean renewable energy solutions and is a barrier to energy efficiency measures. The amount of nuclear generated base-load in the Slovak electricity grid is so high, that proposed investments in wind energy projects by the utility ENEL had to be canceled.

Because of the need to sell the overload of capacity from its nuclear power stations, Slovakia has only marginally invested in energy efficiency measures in the electricity sector.

Hungary excluded from 30 km zone

The Environmental Impact Assessment (EIA) defines an emergency zone of 30 km., with the exception of a part that is Hungarian territory. With this, Hungarian citizens are submitted to another analysis and protection than Slovak citizens. A group of local mayors and the Hungarian NGOs Energia Klub and Greenpeace criticised this issue during the public participation.

No attention for gender effects in EIA
The effects of radiation on vulnerable groups, especially pregnant women and small children, was not taken into account in the Environmental Impact Assessment. Radiation effects were only indicated in general terms.

Nuclear risk export
In a plebiscite in 1987 Italy decided to close down all of its nuclear reactors due to safety concerns. As the Italian government has a 30% stake in ENEL, the utility company's engagement with the Mochovce 3&4 project is a clear example of nuclear risk export.