President of the EU Commission Ursula von der Leyen
Secretary of State Antony J. Blinken, USA Department of State
EU Energy Commissioner Kadri Simson
Federal Chancellor of Germany Olaf Scholz
Prime Minister of the United Kingdom Rishi Sunak
Prime Minister of Poland Donald Tusk
Prime Minister of Ireland Leo Varadkar
Prime Minister of Denmark Mette Frederiksen
Prime Minister of Estonia Kaja Kallas
Prime Minister of Latvia Evika Silina
Prime Minister of Lithuania Ingrida Šimonytė
An open letter to politicians, officials and the public regarding the need to prevent the Russian wind energy industry from evading the sanctions regime, as its profits are used to continue the aggressive war in Ukraine.
We sincerely thank you for your comprehensive support of and assistance to Ukraine in confronting the aggressor and jointly defending European values, rights and freedoms from Russian aggression, which has destroyed peace in Europe and still threatens the entire European community with further escalation. The fight for peace and stability in Europe takes a heavy toll on every Ukrainian every day.
As representatives of the civil society in Ukraine and Europe, we are extremely concerned that despite the previously imposed sanctions, the Russian wind energy companies continue using modern innovative Western technologies for their own economic growth and profits from export projects, while circumventing the sanctions.
In 2022-2023, such key European wind turbine manufacturers and wind project investors as Vestas, Siemens Gamesa, Fortum, Enel officially left Russia. The European Union finally imposed direct restrictions on the supply of components, including those used for the production of wind turbines, as part of the fifth package of sanctions, which came into force on 10 July 2022. The sanctions imposed restrictions on the sale or supply of wind turbines to any individuals or legal entities in the Russian Federation or for use in the Russian Federation, as well as on the supply of electronic components, software, and transport equipment.
Nevertheless, the Russian companies that are part of the state-owned RosAtom corporation take advantage of the lack of effective control over the compliance with the sanctions regime. They continue developing new wind projects and manufacturing wind turbines in Russia using Western components, in particular, the NovaWind company at the Atommash plant, which operates on the basis of the technologies of the Dutch enterprise Lagerway, which was acquired by the German company Enercon in 2018 (the only model of the Enercon E-70 Lagerwey wind turbine with a capacity of 2.5 MW is assembled in Russia). According to journalists, components for the production of the main technological units (blades, nacelles, generators, converters) are still mostly made in Europe. NovaWind implements such projects using funds received from another Russian state corporation, Gazprombank.
Most of the German technology companies that produce parts, electronics and components for Russian wind turbines (such as ABB, Liebherr, Bosch) continue operating in Russia and paying taxes to the aggressor’s military budget. Moreover, all foreign companies that have not left the Russian market take advantage of the reduced competition due to the withdrawal of other companies and sometimes even occupy a monopoly position, for example, in terms of supplying technological components. At the same time, the aforementioned German wind turbine manufacturer, Enercon, received direct support from the German government in the amount of EUR 500 million in July 2022.
When the 12th EU sanctions package came into force, the sanctioned goods were extended to include batteries, design software, machine tools and parts for machinery. All these components and software are critical for the production of wind turbines.
In view of the above stated, we urge you to:
– to join efforts to curb the growth of economic power of the Russian state corporation RosAtom, which is one of the key enterprises that contribute to the Russian military budget;
– to impose sanctions on its structural unit, NovaWind, for evading compliance with the sanctions imposed by the EU and the US;
– to strengthen control over the compliance with sanctions by companies in the market, as well as to strictly warn European and other companies that facilitate the circumvention of sanctions by Russia by providing services, software, technologies, and components to the sanctioned sectors of the Russian economy.
For almost 2 years, the aggressor country has been allocating all its resources to continue the brutal and bloody expansion war in Ukraine. Indulgence of the aggressor reduces the chances of gaining security, peace and stability for European countries.
1. NGO Energy Agency Alternative
2. NGO Social Initiative City of the Sun
3. NGO “Rivne Social Partnership Center
4. NGO Agency of Journalistic Investigations Fourth Estate
5. NGO All-Ukrainian Sustainable Development & Investment Agency
6. NGO Hromadske Volyn
7. NGO Razom We Stand
8. NGO Ecoaction
9. NGO Khmelnytskyi Energy Cluster
10. Energy Transition Coalition
11. ZMINA Human Rights Center
12. Rivne oblast organization of the All-Ukrainian NGO Civil Network OPORA
The letter was prepared within the framework of the project Monitoring and pushing for sanctions against Russian energy sources with the support of the Grassroots foundation.