1 D4 Highway, Ivanka North - Záhorská Bystrica Final Opinion: (Number: 292/2011-7.3/ml) issued by the Ministry of Environment of the Slovak Republic under Act No. 24/2006 Coll. on the Environmental Impact Assessment amending and supplementing other acts as amended I. BASIC INFORMATION ON CLAIMANT 1. Name Národná diaľničná spoločnosť, a.s. 2. Identification No. 35919 001 3. Registered office Mlynské Nivy 45, 821 09 Bratislava II. Basic Data on the Intention 1. Name D4 Highway, Ivanka North - Záhorská Bystrica 2. Purpose The highway D4 represents a traffic link of the existing D1 and D2 highways in the southern, eastern and northern part of Bratislava, the capital of the Slovak Republic, while the affected area is extremely complicated also in terms of transport relations and linkages within the region of the "Great Bratislava" due to the rapid development of the subregion and constantly changing activities and functions in this extremely attractive area, where it is crucial to determine transport requirements and connections to the existing road system. In addition to the D2 and D1 highway connection, D4 will be a major international interconnection between Slovakia and Austria with transport links to Hungary and the Czech Republic. The highway D4 is currently in operation starting from the border between Austria and Slovakia up to the interchange of D4 and D2 Jarovce, covering 2.7 km. Also in operation at 1/2 of the profile is the highway D4 Záhorská Bystrica - Devínska Nová Ves (interchange Stupava South), which is 3.2 km long. According to the technical documentation (Feasibility and Suitability Study for Route of Highway D4, Dopravoprojekt 2009), the highway D4 in the section Ivanka South - Záhorská Bystrica is the section II of the highway D4, which is currently being prepared, while all the route of D4 is divided according to the mentioned documentation as follows: I. D4 Highway section Jarovce – Ivanka North II. D4 Highway section Ivanka North - Záhorská Bystrica III. D4 Highway section Záhorská Bystrica - Devínska Nová Ves
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D4 Highway, Ivanka North - Záhorská Bystrica
Final Opinion:
(Number: 292/2011-7.3/ml)
issued by the Ministry of Environment of the Slovak Republic under Act No. 24/2006 Coll. on
the Environmental Impact Assessment amending and supplementing other acts as amended
I. BASIC INFORMATION ON CLAIMANT
1. Name
Národná diaľničná spoločnosť, a.s.
2. Identification No.
35919 001
3. Registered office
Mlynské Nivy 45, 821 09 Bratislava
II. Basic Data on the Intention
1. Name
D4 Highway, Ivanka North - Záhorská Bystrica
2. Purpose
The highway D4 represents a traffic link of the existing D1 and D2 highways in the southern,
eastern and northern part of Bratislava, the capital of the Slovak Republic, while the affected
area is extremely complicated also in terms of transport relations and linkages within the region
of the "Great Bratislava" due to the rapid development of the subregion and constantly changing
activities and functions in this extremely attractive area, where it is crucial to determine transport
requirements and connections to the existing road system. In addition to the D2 and D1 highway
connection, D4 will be a major international interconnection between Slovakia and Austria with
transport links to Hungary and the Czech Republic.
The highway D4 is currently in operation starting from the border between Austria and Slovakia
up to the interchange of D4 and D2 Jarovce, covering 2.7 km. Also in operation at 1/2 of the
profile is the highway D4 Záhorská Bystrica - Devínska Nová Ves (interchange Stupava South),
which is 3.2 km long.
According to the technical documentation (Feasibility and Suitability Study for Route of
Highway D4, Dopravoprojekt 2009), the highway D4 in the section Ivanka South - Záhorská
Bystrica is the section II of the highway D4, which is currently being prepared, while all the
route of D4 is divided according to the mentioned documentation as follows:
I. D4 Highway section Jarovce – Ivanka North
II. D4 Highway section Ivanka North - Záhorská Bystrica
III. D4 Highway section Záhorská Bystrica - Devínska Nová Ves
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IV. D4 Highway section Devínska Nová Ves - border Slovakia/Austria in operation in 1/2 of
the profile from August, 1, 2011.
In the context of the mentioned facts, the purpose of the proposed action, in addition to
improving conditions for international and domestic transit traffic, shall also be to increase the
flow, speed and safety of all road users, with simultaneous reduction of the negative impact of
the existing road transport on the environment, particularly in relation to the considerable
environmental impact of the urban agglomeration and the region of "Great Bratislava." The
proposed action will also help the traffic operation of the affected area as well as partially relieve
the central part of Bratislava from transit traffic.
3. User
The structure will be used by vehicle users.
4. Location (Cadastral Territory):
Region: Bratislava
District: Bratislava III, Bratislava IV, Malacky, Senec,
Pezinok
Municipality: Lozorno, Pezinok, Viničné, Slovenský Grob, Chorvátsky
Grob, Bernolákovo, Stupava, Municipal District of
Bratislava - Záhorská Bystrica, Marianka, Borinka,
Municipal District of Bratislava - Rača, Municipal District
of Bratislava - Vajnory, Svätý Jur, Ivanka pri Dunaji
Cadastral territory: Mást I, Záhorská Bystrica I, Bystrická hora, Mást II,
Marianka, Borinka, Rača, Vajnory, Svätý Jur, Ivanka pri
Dunaji Lozorno, Neštich, Svätý Jur, Grinava, Pezinok,
Viničné, Slovenský Grob, Chorvátsky Grob, Bernolákovo
5. Term of Activity Commencement
Expected construction commencement date: year 2014
Expected construction works completion: year 2018
Estimated year of putting into service: year 2018
Estimated year of operation termination: not specified
6. Brief Description of the Technical and Technological Solution
The highway D4 section of Ivanka North -Záhorská Bystrica begins by a connection to the
preceding section D4 Jarovce - Ivanka North at the interchange D4 - D1, ending at the
interchange D4 - I/2 Záhorská Bystrica, which is already in operation within the completed and
operating section D4 Záhorská Bystrica - Devínska Nová Ves in 1/2 of the profile.
This section of the highway D4 is designed in following variants:
variant 7 a - with elevated routing of the highway
b - with subgrade highway routing
c - with subgrade highway routing
- variant 2 a - with elevated highway routing
b - with subgrade highway routing - variant SPL - new corridor lead more northwards, compared to the proposed variants in the
intention on the route Senec, Pezinok, Lozorno.
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Brief technical and technological description of the construction - variants 2a, 2b, 7a, 7b, 7c
The Feasibility Study considered building a multi-level crossing of the highways D4 and D1 under the existing embankment body of the highway D1, including a partial embedding of the highway D4 under the
ground level, thus complying with the standard passage height. In this way, it is necessary to build the
highway D4 in a sealed bathtub in the length of about 600 m because of the high ground water
level. Such solution is related to the crossing of D4 and the relocation of the road I/61, which
was designed above the D4 highway. Before the completion of works on the documentation of
the zoning and planning decision (DZP), the Ministry of Transport, Construction and Regional
Development of the Slovak Republic (hereinafter referred to as the MDVRR SR) changed the
location of the I/61 road routing which remained on the ground level, while the highway D4 was
supposed to be lead above the road I/61. The optional solution of the routing of the highway D4
at the interchange Ivanka North consists in a modification of the elevated routing of the highway
D4, that is above the highway D1 (in order for the D4 to conveniently cross the road I/61 as well
as the highway D1). Therefore, a modification of the vertical alignment from the 21.250 km up
to 22.801 km of the section Jarovce - Ivanka North and from 0.000 km to 0.575 km of the
section Ivanka North - Záhorská Bystrica (in variants 2a, 2b, 7a, 7b, 7c). The vertical alignment
is designed routing by a bridge structure over the highway D1, in order to prevent the sealing
bath construction under the ground water level, which would require demanding construction
technology and disturb the flow and quality of the groundwater during the construction.
Moreover, such a solution allows the highway D1 traffic to continue during the highway D4
construction, despite restrictions. In case of the highway D4 is going to be built under the D1
highway, the D1 would have to be completely closed. According to the source technical
documentation (feasibility and effectiveness study), both variants of the elevated crossing of the
highways D1 and D4 are designed so that the vertical alignment of the highway D4 remains
without changes from 0.575 km on westwards.
At this point, the variants 2 and 7, as well as their modifications, at the assessed highway D4
section begin. Such a solution provides variability of the vertical alignment of the D4 routing in
both directions. At this point, the highway D4 may be routed in direction east to an underpass
under the highway D1, or even to an overpass above the D1 and in direction west by surface
routing (variants 2a, 7a, 7c), or by subgrade routing into the Vajnory tunnel (variant 2b, 7b).
Therefore, it is possible to conclude that the beginning of the assessed section is located behind
the Ivanka North interchange at 0.575 km.
All the variants are designed with the intent to comply with the assessment scope requirements
as much as possible (elevated and subgrade routing of the highway in the section around the
Vajnory municipality and from the west portal up to the FOI Záhorská Bystrica). In case they
locally fail to satisfy such a condition, it is due to the connection to the related section of the
highway D4 Záhorská Bystrica - Devínska Nová Ves, which has already been in operation at
half profile.
The width arrangement of the highway D4 is designed in the category D 26.5/120, and 2T 8.0/80
in the Karpaty and Katušiná tunnels.
Variant 2a – elevated routing of highway in the section around the Vajnory municipality
and between Marianka and the Záhorská Bystrica municipality with the length of 16.840 km.
The variant 2a begins at 0.575 km, where the vertical alignments of both variants of the Ivanka
North interchange meet at the approx. 6 m high embankment. The highway route continues
westwards on the embankment for a short distance, concurrent with the Šúrsky kanál at the
distance of approx. 300 m from the north-east edge of the built-up area of the Vajnory
municipality.
The flyover interchange (FOI) Čierna voda is located at 1.263 km. At this point the highway
crosses the road III/5021 (D4 over III/5021) by a bridge structure and an 8 m high embankment.
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The highway continues concurrently with the Šúrsky kanál on a descending embankment further
towards the eastern slopes of the Little Carpathians. At point 2.524 km the highway crosses
Račiansky potok (Rača creek) by a bridge structure. At point 3.250 km the highway runs closely
above the terrain level and continues on the embankment reaching the height of 5 m before the
FOI Rača.
At the FOI Rača, at point 4.124 km the highway crosses the railroad No.120 Bratislava - Žilina
by a bridge, along with the road II/502 (D4 runs over the railway as well as the road II/502).
In the section between the FOI Ivanka North and FOI Čierna voda, there are designed one-way
two-lane collectors (concurrent roads) of category C 9.5/8 on both sides of the highway D4, to
which the local roads will be connected. In the section between FOI Čierna voda and FOI Rača
the one-way collector is proposed only for the southern part of D4 highway, through which the
adjacent territory west of the Vajnory municipality can be connected (CEPIT premises).
The highway route continues south-west over the FOI Rača passing through vineyards and on a 3
m high embankment, then in a moderate cut, and later again on a 5 m high embankment,
ascending up to the east portal of the Karpaty tunnel. At the section between the FOI Rača and
the tunnel portal, there are four bridge structures over the local roads and terrain depressions.
At 6.213 km the Karpaty tunnel begins by its east portal, by which the highway crosses the Little
Carpathians. The total length of the tunnel is 8.062 km. The west portal is situated at the border
of PLA Little Carpathians, at 14.275 km of the highway D4. The tunnel is equipped with a
ventilation shaft at approx. 10.050 km of the highway D4. The access road to the above-ground
part of the ventilation shaft runs from the Bratislava municipality of Rača along a forest road
around Pieskový potok (Sand creek) under the Biely kríž hill, then by Štefánikova magistrála
road south-west for approx. 2 km, and then in direction west by an unpaved forest road up to the
shaft itself.
Behind the tunnel the routing of the west portal is in a cut of 22 m depth (territory noise impact
minimization) and 1.1 km length. It continues by an embankment reaching the maximum height
of 6 m and a moderate cut over the slope foot of the Mariánske vinohrady site, north of the
municipality of Marianka. At 15.843 km the highway crosses the relocated field road by a
bridge structure.
The variant 2a terminates at the interchange of the highway D4 and the road I/2 FOI Záhorská
Bystrica (D4 over the I/2). At the interchange the highway crosses the road I/2 by a double-arch
bridge.
Proposed interchanges:
- the highway FOI Ivanka North, 0.000 km of the highway D4, designed as a clover leaf
shaped interchange of the highway D1 (6 lane with concurrent roads at both sides, the so
called collectors) and the highway D4 (4 lane with concurrent roads at both sides),
- FOI Čierna voda, 1.263 km of the highway D4, designed as folded diamond/delta shaped
interchange with two roundabouts on the road III/5021, which are left on the ground along
with the road, the roundabouts are connected to collectors, thus joining the highway D4.
- highway FOI Rača designed as a complex double-level shaped interchange at 4.142 km of
the highway D4,
- highway FOI Záhorská Bystrica, at 16.649 km of the highway D4, delta shaped interchange
situated on a local elevation between Stupava and Záhorská Bystrica at 16.649 km of the
highway D4.
Proposed bridges:
Outline of the bridges of the variant 2a:
Bridges over D4 - 3 (length of the bridges - 108 m, 136 m, 76 m)
Bridges over D4 - 6 (length of the bridges - 23.5 m, 10 m, 21 m, 21 m, 10 m, 51 m)
Bridges on a collector - 2 (length of the bridges - 23.5 m, 23.5 m)
5
Bridges on an interchange branch - 1 (length of the bridge - 63 m)
Bridges together: - 12 (total length - 565.5 m)
Proposed tunnels:
In the variant 2a, the Karpaty tunnel of 8.062 km is proposed. Its further specifications follow.
Highway sewerage system: The variant 2a is subdivided into 15 drained sections (excluding the tunnel). There will be 7 pumping stations. Recipients are the creeks Strúha, Šúrsky kanál, Račiansky potok, Podhájsky potok, Mariánsky
potok. After purification in the oil substance separators (ORL), the water from the five drained
sections will be freely absorbed into the soil.
Sewerage sections and their mouths in variant 2a are described in the following table: Drained section (km) Mouths (recipient)
0.000 – 0.500 up to the highway D4 section of Jarovce – Ivanka North
0.500 – 1.200 thou. (left) through ORL and RT into the Strúha creek
0.500 – 1.200 thou. (right) through ORL and RT into the Šúrsky kanál
1.200 – 1.500 thou. (left) through ORL and RT into the Strúha creek
1.200 – 1.500 (right) through ORL and RT into the Šúrsky kanál
1.500 – 2.500 through ORL and RT into the Račiansky creek
2.500 – 4.300 through ORL and RT into the Šúrsky kanál
4.300 – 4.800 through ORL soil absorption
4.800 – 5.400 through ORL soil absorption
5.400 – 6.200 through ORL soil absorption
14.200 – 14.600 through ORL soil absorption
14.600 – 15.100 through ORL soil absorption
15.100 – 15.600 through ORL and RT into the Podhájsky creek
15.600 – 16.600 through ORL and RT into the Mariansky creek
16.600 – 16.840 up to the Highway D4 section of Záhorská Bystrica – Devínska Nová
Ves
Proposed relocations and road changes:
- Relocation of the field road at 3.366 km (over the highway D4), category P 6/40, total length
of 430 m
- The road II/502 modification at the FOI Rača is an enlargement of the existing four-lane,
directionally divided road by adding joining and turning additional lanes of the intersection.
The length of the modification is 1.9 km.
- Relocation of the field road (at the crossing of FOI Rača), category P 6/40, estimated
relocation length is 1.200 km
- Relocation of the field road at 14.500 km of D4 on the right, category P 6/40, 707 m long
- Relocation of the field road (by a bridge over D4 at 15.247 km), category P 6/40, 270 m
long
- Relocation of the field road (under D4 at 15.843 km), category P 6/40, overall length of 270
m
- Walking and cycling path (at 16.559 km of the highway D4) at the intersection of the FOI
Záhorská Bystrica, 5 m wide and 253 m long
Access roads and construction yards:
During the D4 construction, the construction mechanisms will be provided access to the
constructions site, mainly to the large objects construction sites (Karpaty tunnel, bridges and
interchanges). In principle, it is expected that all public roads will be used as main access routes
to get the direct access to the construction site, while prospective suppliers of works will keep on
moving along the D4 route, along the surfaces of the permanent land use of the structure.
The relocation of the1.075km long field road in the vineyards in FOI Rača will be used to access
the east portal of the Karpaty tunnel and it will be connected to the existing field road in the
vineyards, concurrent with the II/502 road. The relocation of the field road at km 14.500 of the
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D4 highway, which is 707m long, together with the highway route D4 will be used to access the
west portal of the Karpaty tunnel. The access road to the above-ground part of the ventilation
shaft runs from the Bratislava municipality of Rača along a forest road around Pieskový creek,
under the Biely kríž hill, then by Štefánikova magistrála road south-west for approx. 2 km, and
then in direction west by an unpaved forest road up to the shaft itself.
Construction yards at the FOI Čierna voda, FOI Rača and FOI Záhorská Bystrica premises, also
at both portals of the Karpaty tunnel.
Variant 2b – subgrade routing of highway in section around the Vajnory municipality
and between Marianka and the Záhorská Bystrica municipality with length of 16.840 km.
Variant 2b commences at point 0.575 km, where the vertical alignments of both variants of the
Ivanka North interchange meet on the embankment at height of approx. 6m. The route of the
highway continues for a short distance on the embankment westwards concurrently with Šúrsky
kanál. In the section running in the vicinity of the built up area of the Vajnory municipality (at
distance of approx. 300 m from the north-eastern edge), the vertical alignment of the highway
continues from point 0.900 km under the level of the terrain up to 1.600 km. It concerns a soil
covered (subgrade) section of the highway named Vajnory tunnel.
At point 1.263 km the flyover interchange (FOI) Čierna voda is located, where the highway D4
crosses the road III/5021 (D4 runs below III/5021).
Behind the tunnel the highway continues concurrently with Šúrsky kanál on the up to 5 m high
embankment towards the eastern slopes of the Little Carpathians. At point 2.524 km the highway
crosses Račiansky potok (Rača creek) by a bridge structure. At point 3.250 km the highway runs
closely above the terrain level and continues on the embankment reaching the height of 5 m
before FOI Rača.
In FOI Rača, at point 4.124 km the highway crosses the railroad No.120 Bratislava - Žilina by a
bridge, along with the road II/502 (D4 runs over the railway as well as the road II/502).
In the section between the FOI Ivanka North and FOI Čierna voda, the one-way two-lane
collectors (concurrent roads) of category C 9,5/80 are designed on both sides of highway D4, to
which the local roads will be connected. In the section between FOI Čierna voda and FOI Rača a
one-way collector is proposed only for the southern part of D4 highway, through which the
adjacent territory west of the Vajnory municipality can be connected (CEPIT premises).
The highway route continues south-west over the FOI Rača passing through vineyards and on a 3
m high embankment, then in a moderate cut, and later again on a 5 m high embankment,
ascending up to the east portal of the Karpaty tunnel. At the section between the FOI Rača and
the tunnel portal, there are four bridge structures over the local roads and terrain depressions.
At 6.213 km the Karpaty tunnel begins by its east portal, by which the highway crosses the Little
Carpathians. Compared to the variant 2a, the tunnel is prolonged at the west portal, reaching the
total length of 9.055km, up until the west edge of the built-up area of the Marianka municipality.
The tunnel is equipped with a ventilation shaft at approx. 10.050 km of the highway D4. The
access road to the above-ground part of the ventilation shaft runs from the Bratislava
municipality of Rača along a forest road around Pieskový creek, under the Biely kríž hill, then
by Štefánikova magistrála road south-west for approx. 2 km, and then in direction west by an
unpaved forest road up to the shaft itself. After the exit from the Little Carpathians (at 15.268 km), the highway D4 runs in a deep cut (subgrade routing), in the form of a soil covered tunnel, while the entire Karpaty tunnel is prolonged by approx. 0.600 km. Behind the tunnel the route continues by an embankment of the maximum height of 9 m at the foot of
the slopes of the municipal district of Mariánske vinohrady north from the Marianka municipality. The
embankment route is due to the necessity of drainage of the highway and gradual connection to
the FOI Záhorská Bystrica, which is already being built. At 15.843 km the highway crosses the
relocated field road by a bridge structure.
The section terminates at the interchange of the highway D4 and the road I/2 FOI Záhorská
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Bystrica (D4 over the I/2). At the interchange the highway crosses the road I/2 by a double-arch
bridge.
Proposed interchanges:
- the highway FOI Ivanka North, 0.000 km of the highway D4, designed as a clover leaf
shaped interchange of the highway D1 (6 lane with concurrent roads at both sides, the so
called collectors) and the highway D4 (4 lane with concurrent roads at both sides),
- FOI Čierna voda, 1.263 km of the highway D4, designed as delta shaped interchange with
two roundabouts on the road III/5021, which are left on the ground and connected by a
bridge structure over the highway D4 (in the tunnel), the roundabouts are connected to the
collectors, thus joining the highway D4,
- highway FOI Rača designed as a complex double-level shaped interchange at 4.142 km of
the highway D4,
- highway FOI Záhorská Bystrica, a delta shaped interchange situated on a local elevation
between Stupava and Záhorská Bystrica at 16.649 km of the highway D4.
Proposed bridges:
Outline of the variant 2b bridges:
Bridges over D4 - 2 (length of the bridges - 108 m, 108 m)
Bridges over D4 - 6 (length of the bridges - 23.5 m, 21 m, 21 m, 7 m, 10 m, 51 m)
Bridges on a collector - 2 (length of the bridges - 23.5 m, 23.5 m)
Bridges on an interchange branch - 1 (length of the bridge - 63 m)
Bridges together: - 11 (total length - 459.5 m)
Proposed tunnels:
In the variant 2B the proposed Karpaty tunnel is 9.055 km long, while the soil covered Vajnory
tunnel is 0.700 m long. Their further specification follow.
Highway sewerage system:
The variant 2a is subdivided into 10 drained sections (excluding the tunnel). There will be 6
pumping stations. Recipients are the creeks Strúha, Šúrsky kanál, Račiansky potok, Podhájsky
potok, Mariánsky potok. After purification in the oil substance separators (ORL), the water from
the three drained sections will be freely absorbed into the soil.
Sewerage sections and their mouths in variant 2a are described in the following table: Drained section (km) Mouths (recipient)
0.000 – 0.600 up to the Highway D4 section of Jarovce – Ivanka North
0.600 - 2.200 thou. (left) through ORL and RT into the Strúha creek
0.600 - 2.200 (right) through ORL and RT into the Šúrsky kanál
2.200 – 4.300 through ORL and RT into the Šúrsky kanál
4.300 – 4.800 through ORL soil absorption
4.800 – 5.400 through ORL soil absorption
5.400 – 6.200 through ORL soil absorption
15.250 – 15.600 through ORL and RT into the Podhájsky creek
15.600 – 16.600 through ORL and RT into the Mariansky creek
16.600 – 16.840 up to the Highway D4 section of Záhorská Bystrica – Devínska Nová
Ves
Proposed relocations and road changes:
- Relocation of the road III/5021 (over the highway D4 at 1.262 km), category C 7.5/50, 305
m long. Two roundabouts are part of the adjustment.
- Bypass on the road III/5021 (temporary bypass at 1.262 km), category C 7.5/50, of the
length of 550 m.
- Relocation of the field road (over D4 at 3.366 km), category P 6/40, overall length of 430 m
8
- The road II/502 modification at the FOI Rača is an enlargement of the existing four-lane,
directionally divided road by adding joining and turning lanes to the intersection. The length
is 1.900 km.
- Relocation of the field road (at the crossing of FOI Rača), category P 6/40, estimated
relocation length is 1.200 km
- Relocation of the field road at 14.500 km of D4 on the right, category P 6/40, 707 m long
- Relocation of the field road (over the west portal of the Karpaty tunnel at 15.247 km of the
D4 highway), category P 6/40, 270 m long
- Relocation of the field road (under D4 at 15.843 km), category P 6/40, overall length of 270
m
- Construction of a walking and cycling path (at 16.559 km of D4 highway) at the crossing of
Záhorská Bystrica, 5 m wide and 253 m long
Access roads and construction yards:
During the D4 construction, the construction mechanisms will be provided access to the
constructions site, mainly to the large objects construction sites (Karpaty tunnel, bridges and
interchanges). In principle, it is expected that all public roads will be used as main access routes
to get direct access to the construction site, while prospective suppliers of works will keep on
moving along the D4 route, along the surfaces of the permanent land use of the structure.
The relocation of the1.075km long field road in the vineyards in FOI Rača will be used to access
the east portal of the Karpaty tunnel and it will be connected to the existing field road in the
vineyards, concurrent with the II/502 road. The relocation of the field road at km 14.500 of the
D4 highway, which is 707m long, together with the highway route D4 will be used to access the
west portal of the Karpaty tunnel. The access road to the above-ground part of the ventilation
shaft runs from the Bratislava municipality of Rača along a forest road around Pieskový creek,
under the Biely kríž hill, then by Štefánikova magistrála road south-west for approx. 2 km, and
then in direction west by an unpaved forest road up to the exhaust itself.
Construction yards at the FOI Čierna voda, FOI Rača and FOI Záhorská Bystrica premises, also
at both portals of the Karpaty tunnel.
Variant 7a – elevated routing of highway in section around the Vajnory municipality
and between Marianka and the Záhorská Bystrica municipality with the length of 16.722
km.
The variant 7a begins at 0.575 km, where the vertical alignments of both variants of the Ivanka
North interchange meet at the approx. 6 m high embankment. The highway route continues
westwards on the embankment, concurrent with the Šúrsky kanál at the distance of approx. 300
m from the north-east edge of the built-up area of the Vajnory municipality.
FOI Čierna voda is situated at 1.263 km, where the highway crosses the road III/5021 (D4 over
III/5021) by a bridge structure and an 8 m high embankment.
The highway continues to run concurrently with the Šúrsky kanál on the descending
embankment towards the eastern slopes of the Little Carpathians. At point 2.524 km the highway
crosses Račiansky potok (Rača creek) by a bridge structure. At point 3.250 km the highway runs
closely above the terrain level and continues on the embankment, whose height is 8 m before
FOI Rača.
In the section between FOI Ivanka North and FOI Čierna voda, the one way two-lane collectors
(concurrent roads) of category C 9,5/80 are designed on both sides of highway D4, to which the
local roads will be connected. In the section between FOI Čierna voda and FOI Rača a one-way
collector is proposed only for the southern part of D4 highway, through which the adjacent
territory west of the Vajnory municipality can be connected (CEPIT premises).
When compared to variants 2a, 2b, the FOI Rača is shifted more northwards, while the highway
D4 crosses the railway No. 120 Bratislava - Žilina and road II/502 (D4 runs over both the
railway and road II/502). At point 3.765 km ahead of the interchange it crosses the relocated
9
field road by a bridge. Behind the short, approx. 250 m long, embankment up to 11 m high there
is a bridge over the interchange branch and other two bridge structures of the interchange.
Behind the interchange the vertical alignment reaches the terrain level and it is transformed into
a 300 m long cut.
The east portal of the Karpaty tunnel is located at 4.7 km. The total length of the tunnel is 9.950
km. The west portal is situated behind the forest edge north of the Marianka municipality at
14.650 km. The tunnel is equipped with a ventilation shaft at approx. 10.050 km of the highway
D4. The access road to the above-ground part of the ventilation shaft runs from the Bratislava
municipality of Rača along a forest road around Pieskový creek, under the Biely kríž hill, and
then in direction west by an unpaved forest road for approx. 2 km up to the exhaust itself.
Behind the tunnel the routing from the west portal runs in a cut of 11 m depth (minimization of
the territory noise impact). Then, up to the FOI Záhorská Bystrica the vertical alignment of the
highway runs over the ground. The maximum height of the embankment reaches 6 m in this
section. At 15.775 km the highway D4 crosses a relocation of a field road by a bridge. The
variant 7a terminates at the FOI Záhorská Bystrica (D4 over I/2) with a bridge construction.
Proposed interchanges:
- the highway FOI Ivanka North, 0.000 km of the highway D4, designed as a clover leaf
shaped interchange of the highway D1 (6 lane with concurrent roads at both sides, the so
called collectors) and the highway D4 (4 lane with concurrent roads at both sides),
- FOI Čierna voda, 1.263 km of the highway D4, designed as folded diamond/delta shaped
interchange with two roundabouts on the road III/5021, which are left on the ground along
with the road, the roundabouts are connected to collectors, thus joining the highway D4.
- highway FOI Rača designed as a complex double-level shaped interchange at 4.142 km of
the highway D4,
- highway FOI Záhorská Bystrica, a delta shaped interchange situated on the road I/2 on a
local elevation between Stupava and Záhorská Bystrica at 16.581 km of the highway D4.
Proposed bridges:
Outline of the variant 7a bridges:
Bridges over D4 - 2 (length of the bridges - 108 m, 76 m)
Bridges over D4 - 7 (length of the bridges - 23.5 m, 10 m, 21 m, 21 m, 7 m, 10 m, 51 m)
Bridges on a collector - 2 (length of the bridges - 23.5 m, 23.5 m)
Bridges on an interchange branch - 1 (length of the bridge - 63 m)
Bridges together: - 12 (total length - 437.5 m)
Proposed tunnels:
In the variant 7a, the Karpaty tunnel is proposed in the length of 9.950 km. Its further
specifications follow.
Highway sewerage system:
The variant 7a is subdivided into 12 drained sections (excluding the tunnel). There will be 7
pumping stations. Recipients are the creeks Strúha, Šúrsky kanál, Račiansky potok, Podhájsky
potok, Mariánsky potok. After the purification at ORL, the water coming from the two drained
sections is meant to be absorbed.
Sewerage sections and their mouths in variant 7a are outlined in the following table: Drained section (km) Mouths (recipient)
0.000 – 0.500 up to the Highway D4 section of Jarovce – Ivanka North
0.500 – 1.200 thou. (left) through ORL and RT into the Strúha creek
0.500 – 1.200 thou. (right) through ORL and RT into the Šúrsky kanál
1.200 – 1.500 thou. (left) through ORL and RT into the Strúha creek
1.200 – 1.500 (right) through ORL and RT into the Šúrsky kanál
1.500 – 2.500 through ORL and RT into the Račiansky creek
2.500 – 4.400 through ORL and RT into the Šúrsky kanál
4.400 – 4.700 through ORL soil absorption
10
14.650 – 15.100 through ORL soil absorption
15.100 – 15.600 through ORL and RT into the Podhájsky creek
15.600 – 16.500 through ORL and RT into the Mariansky creek
16.500 – 16.770 up to the Highway D4 section of Záhorská Bystrica – Devínska Nová
Ves
Proposed relocations and road changes:
- Relocation of the field road (under D4 at 3.765km), category P 6/40, overall length of 680 m
- The road II/502 modification at the FOI Rača is an enlargement of the existing four-lane,
directionally divided road by adding joining and turning lanes to the intersection. The length
is 1.998 km.
- Relocation of the field road (at the crossing of FOI Rača), category P 6/40, estimated
relocation length is 1.200 km
- Relocation of the field road at 14.500 km of D4 on the right, category P 6/40, 707 m long
- Relocation of the field road (over the D4 highway at 15.179 km), category P 6/40, 270 m
long
- Relocation of the field road (under D4 at 15.775km), category P 6/40, overall length of 270
m
- Construction of a walking and cycling path (at 16.559km of D4 highway) at the crossing of
FOI Záhorská Bystrica, 5 m wide and 253 m long
Access roads and construction sites:
During the D4 construction, the construction mechanisms will have access to the construction
sites, mainly to the large objects construction (the Karpaty tunnel, bridges and interchanges). In
principle, it is expected that all public roads will be used as main access routes to get direct
access to the construction site, while prospective suppliers of works will keep on moving along
the D4 route, along the surfaces of the permanent land use of the structure.
The relocation of the1.2 km long field road will be used to access the east portal of the Karpaty
tunnel and it will be connected to the existing field road in the vineyards, concurrent with the
II/502 road. The relocation of the field road at km 14.500 of the D4 highway, which is 707m
long, and the highway D4 route will be used to access the west portal of the Karpaty tunnel.
The access road to the above-ground part of the ventilation shaft runs from the Bratislava
municipality of Rača along a forest road around Pieskový creek, under the Biely kríž hill, then
by Štefánikova magistrála road south-west for approx. 2 km, and then in direction west by an
unpaved forest road up to the shaft itself.
Construction yards at the FOI Čierna voda, FOI Rača and FOI Záhorská Bystrica premises, also
at both portals of the Karpaty tunnel.
Variant 7c – subgrade routing of highway in section around the Vajnory municipality
and between Marianka and the Záhorská Bystrica municipality with length of 16.772 km.
The variant 7c begins at 0.575 km, where the vertical alignments of both variants of the Ivanka
North interchange meet at the approx. 6 m high embankment. The highway route continues
westwards on the embankment for a short distance, concurrent with the Šúrsky kanál. In the
section running in the vicinity of the built-up area of the Vajnory municipality (at the distance of
approx. 300 m from the north-eastern edge), the vertical alignment of the highway continues
from point 0.900 km under the level of the terrain up to 1.600 km. It concerns a soil covered
(subgrade) section of the highway named Vajnory tunnel.
At point 1.263 km the flyover interchange (FOI) Čierna voda is located, where the highway D4
crosses the road III/5021 (D4 runs below III/5021).
Behind the tunnel the highway continues concurrently with the Šúrsky kanál on the 5 m high
embankment towards the eastern slopes of the Little Carpathians.
At point 2.524 km the highway crosses Račiansky potok (Rača creek) by a bridge structure. At
point 3.250 km the highway runs closely above the terrain level and continues on the
11
embankment, whose height is 8 m before FOI Rača.
In the section between FOI Ivanka North and FOI Čierna voda, the one way two-lane collectors
(concurrent roads) of category C 9,5/80 are designed on both sides of highway D4, to which the
local roads will be connected. In the section between FOI Čierna voda and FOI Rača a one-way
collector is proposed only for the southern part of D4 highway, through which the adjacent
territory west of the Vajnory municipality can be connected (CEPIT premises).
When compared to variants 2a, 2b, FOI Rača is shifted more northwards, while highway D4
crosses railway No. 120 Bratislava - Žilina and road II/502 (D4 runs over both the railway and
road II/502). At point 3.765 km ahead of the interchange, it crosses the relocated field road by a
bridge. Behind the short, approx. 250 m long, embankment reaching the height of 11 m, there is
a bridge over the interchange branch and other two bridge structures of the interchange. Behind
the interchange the vertical alignment reaches the terrain level and it is transformed into a 300 m
long cut.
At 4.700 km, there is the east portal of the Karpaty tunnel, with the depth of the cut reaching 15
m before the tunnel. The total tunnel length in this variant is 10.5 km. The west portal is located
at the west end of the built-up area of the Marianka municipality at 15.2 km. The tunnel is
equipped with a ventilation shaft at approx. 10.050 km of the highway D4. The access road to
the above-ground part of the ventilation shaft runs from the Bratislava municipality of Rača
along a forest road around Pieskový creek, under the Biely kríž hill, and then in direction west by
an unpaved forest road up to the shaft itself.
After exiting the Little Carpathias, the highway D4 runs in a deep cut (subgrade routing) in the
form of a soil covered tunnel, while the length of the Karpaty tunnel results to be prolonged by
approx. 600m. Behind the tunnel the highway D4 runs on in a cut (subgrade) up to approx. 15.7
km. Up until the FOI Záhorská Bystrica the vertical alignment of the highway D4 runs slightly
over the ground. The maximum height of the embankment reaches 6 m in this section. The
embankment route choice is caused by the necessity of the highway D4 drainage and
uninterrupted connection to the FOI Záhorská Bystrica, which is already being built. At point
15.775 km the D4 highway runs above a relocated field road. The variant 7b terminates in FOI
(D4 over I/2) with a bridge construction.
Proposed interchanges:
- the highway FOI Ivanka North, 0.000 km of the highway D4, designed as a clover leaf
shaped interchange of the highway D1 (6 lane with concurrent roads at both sides, the so
called collectors) and the highway D4 (4 lane with concurrent roads at both sides),
- FOI Čierna voda, 1.263 km of the highway D4, designed as folded diamond/delta shaped
interchange with two roundabouts on the road III/5021, which are left on the ground and
connected by a bridge structure over the highway D4 (in the tunnel), the roundabouts are
connected to the collectors, thus joining the highway D4,
- highway FOI Rača designed as a complex double-level shaped interchange at 4.142 km of
the highway D4,
- highway FOI Záhorská Bystrica, at 16.649 km of the highway D4, delta shaped interchange
situated on a local elevation between Stupava and Záhorská Bystrica at 16.649 km of the
highway D4.
Proposed bridges:
Outline of the variant 7b bridges:
Bridges over D4 - 2 (length of the bridges - 108 m, 108 m)
Bridges over D4 - 6 (length of the bridges - 23.5 m, 21 m, 21 m, 7 m, 10 m, 51 m)
Bridges on a collector - 2 (length of the bridges - 23.5 m, 23.5 m)
Bridges on an interchange branch - 1 (length of the bridge - 63 m)
Bridges together: - 11 (total length - 459.5 m)
12
Proposed tunnels:
In the variant 7b the proposed Karpaty tunnel is 10.5 km long, while the soil covered Vajnory
tunnel is 0.700 m long. Their further specification follow.
Highway sewerage system:
The variant 7b is subdivided into 8 drained sections (excluding the tunnel). There will be 6
pumping stations. Recipients are the creeks Strúha, Šúrsky kanál, Račiansky potok, Podhájsky
potok, Mariánsky potok. After purification in the oil substance separators (ORL), the water from
the drained section will be freely absorbed into the soil.
Sewerage sections and their mouths in variant 7b are described in the following table: Drained section (km) Mouths (recipient)
0.000 – 0.600 up to the Highway D4 section of Jarovce – Ivanka North
0.600 - 2.200 thou. (left) through ORL and RT into the Strúha creek
0.600 - 2.200 (right) through ORL and RT into the Šúrsky kanál
2.200 – 4.400 through ORL and RT into the Šúrsky kanál
4.400 – 4.700 through ORL soil absorption
15.200 – 15.600 through ORL and RT into the Podhájsky creek
15.600 – 16.500 through ORL and RT into the Mariansky creek
16.500 – 16.770 up to the Highway D4 section of Záhorská Bystrica – Devínska
Nová Ves
Proposed relocations and road changes:
- Relocation of the road III/5021 (over the highway D4 at 1.262 km), category C 7.5/50, 305
m long. Two roundabouts are part of the adjustment.
- Bypass on the road III/5021 (temporary bypass at 1.262 km), category C 7.5/50, of the
length of 550 m.
- Relocation of the field road (under the D4 highway at 3.765 km), category P 6/40, 680 m
long
- The road II/502 modification at the FOI Rača is an enlargement of the existing four-lane,
directionally divided road by adding joining and turning lanes to the intersection. The length
is 1.998 km.
- Relocation of the field road (at the crossing of FOI Rača), categ. P 6/40, estimated relocation
length is 1.200 km
- Relocation of the field road at 14.500 km of D4 on the right, categ. P 6/40, 707 m long
- Relocation of the field road (over the west portal of the Karpaty tunnel at 15.179 km of the
D4 highway), categ. P 6/40, 270 m long
- Relocation of the field road (under D4 at 15.775km), categ. P 6/40, overall length of 270m
- Construction of a walking and cycling path (at 16.559km of D4 highway) at the crossing of
Záhorská Bystrica, 5m wide and 253m long
Access roads and construction yards:
During the D4 construction, the construction mechanisms will be provided access to the
constructions site, mainly to the large objects construction sites (Karpaty tunnel, bridges and
interchanges). In principle, it is expected that all public roads will be used as main access routes
to get direct access to the construction site, while prospective suppliers of works will keep on
moving along the D4 route, along the surfaces of the permanent land use of the structure.
The relocation of the1.2km long field road will be used to access the east portal of the Karpaty
tunnel and it will be connected to the existing field road in the vineyards, concurrent with the
II/502 road. The relocation of the field road at km 14.500 of the D4 highway, which is 707m
long, and the highway D4 route will be used to access the west portal of the Karpaty tunnel.
The access road to the above-ground part of the ventilation shaft runs from the Bratislava
municipality of Rača along a forest road around Pieskový creek, under the Biely kríž hill, then
by Štefánikova magistrála road south-west for approx. 2 km, and then in direction west by an
unpaved forest road up to the shaft itself.
13
Construction yards at the FOI Čierna voda, FOI Rača and FOI Záhorská Bystrica premises, also
at both portals of the Karpaty tunnel.
Variant 7c – elevated routing of highway around the Vajnory municipality and subgrade
routing of highway in section between Marianka and the Záhorská Bystrica municipality
with length of 16.772 km.
The variant 7c begins at 0.575 km, where the vertical alignments of both variants of the Ivanka
North interchange meet at the approx. 6 m high embankment. The highway route continues
westwards on the embankment for a short distance, concurrent with the Šúrsky kanál at the
distance of approx. 300 m from the north-east edge of the built-up area of the Vajnory
municipality.
FOI Čierna voda is situated at 1.263 km, where the highway crosses the road III/5021 (D4 over
III/5021) by a bridge structure and an 8 m high embankment.
The highway continues concurrently with Šúrsky kanál on the decreasing embankment towards
the eastern slopes of the Little Carpathians. At point 2.524 km the highway crosses Račiansky
potok (Rača creek) by a bridge structure. At point 3.250 km the highway runs closely above the
terrain level and continues on the embankment, whose height is 8 m before FOI Rača.
In the section between FOI Ivanka North and FOI Čierna voda, the one way two-lane collectors
(concurrent roads) of category C 9,5/80 are designed on both sides of highway D4, to which the
local roads will be connected. In the section between FOI Čierna voda and FOI Rača a one-way
collector is proposed only for the southern part of D4 highway, through which the adjacent
territory west of the Vajnory municipality can be connected (CEPIT premises).
When compared to variants 2a, 2b, the FOI Rača is shifted more northwards, while the highway
D4 crosses the railway No. 120 Bratislava - Žilina and the road II/502 (D4 runs over both the
railway and road II/502). Compared to the variants 7a and 7b, the shape of the FOI Rača is
different in variant 7c, even while maintaining identical direction route. All the interchange
ramps are located west from the road II/502. In this solution of the interchange, the highway D4
runs only through one bridge over the railway and the road II/502. Before the interchange at
3.765 km, the highway crosses a relocated field road by a bridge.
The highway, after the interchange, runs on an embankment reaching 9 m of height and
gradually passes into a cut up to the east portal of the Karpaty tunnel at 4.7 km, where the cut is
approximately 15 m deep.
According to this variant, the total length of the tunnel is 10.5 m (the same as in the variant 7b).
The west portal is located over the west end of the built-up area of the Marianka municipality at
15.2 km of the highway D4. The tunnel is equipped with a ventilation shaft at approx. 10.050 km
of the highway D4. The access road to the above-ground part of the ventilation shaft runs from
the Bratislava municipality of Rača along a forest road around Pieskový creek, under the Biely
kríž hill, and then in direction west by an unpaved forest road up to the shaft itself.
After exiting the Little Carpathias, the highway D4 runs in a deep cut (subgrade routing) in the
form of a soil covered tunnel, while the length of the Karpaty tunnel results to be prolonged by
approx. 600m. Behind the tunnel the highway D4 runs on in a cut (subgrade) up to approx. 15.7
km. Up until the FOI Záhorská Bystrica the vertical alignment of the highway D4 runs slightly
over the ground. The maximum height of the embankment reaches 6 m in this section. The
embankment route choice is caused by the necessity of the highway D4 drainage and
uninterrupted connection to the FOI Záhorská Bystrica, which is already being built. At point
15.775 km the D4 highway runs above the relocated field road. The variant 7c terminates in the
FOI Záhorská Bystrica (D4 over I/2) with a bridge construction.
Proposed interchanges:
- the highway FOI Ivanka North, 0.000 km of the highway D4, designed as a clover leaf
shaped interchange of the highway D1 (6 lane with concurrent roads at both sides, the so
called collectors) and the highway D4 (4 lane with concurrent roads at both sides),
14
- FOI Čierna voda, 1.263 km of the highway D4, designed as a delta shaped interchange with
two roundabouts on the road III/5021, which are left on the ground along with the road, the
roundabouts are connected to collectors, thus joining the highway D4.
- highway FOI Rača designed as a complex double-level shaped interchange at 4.142 km of
the highway D4,
- highway FOI Záhorská Bystrica, at 16.649 km of the highway D4, delta shaped interchange
situated on a local elevation between Stupava and Záhorská Bystrica at 16.649 km of the
highway D4.
Proposed bridges:
Outline of the variant 7c bridges:
Bridges over D4 - 2 (length of the bridges - 108 m, 76 m)
Bridges over D4 - 8 (length of the bridges - 23.5 m, 10 m, 21 m, 21 m, 7 m, 115 m,
10 m, 51 m)
Bridges on a collector - 3 (length of the bridges - 23.5 m, 23.5 m, 115 m)
Bridges on an interchange branch - 4 (length of the bridges - 63 m, 70 m, 70 m, 70 m)
Bridges together: - 17 (total length - 777.5 m)
Proposed tunnels:
In the variant 7c, the Karpaty tunnel is proposed in the length of 10.5 km. Its further
specifications follow.
Highway sewerage system:
The variant 7c is subdivided into 11 drained sections (excluding the tunnel). There will be 7
pumping stations. Recipients are the creeks Strúha, Šúrsky kanál, Račiansky potok, Podhájsky
potok, Mariánsky potok. After purification in the oil substance separators (ORL), the water from
the drained section will be freely absorbed into the soil.
Sewerage sections and their mouths in variant 7c are described in the following table: Drained section (km) Mouths (recipient)
0.000 – 0.500 up to the Highway D4 section of Jarovce – Ivanka North
0.500 – 1.200 thou. (left) through ORL and RT into the Strúha creek
0.500 – 1.200 thou. (right) through ORL and RT into the Šúrsky kanál
1.200 – 1.500 thou. (left) through ORL and RT into the Strúha creek
1.200 – 1.500 (right) through ORL and RT into the Šúrsky kanál
1.500 – 2.500 through ORL and RT into the Račiansky creek
2.500 – 4.200 through ORL and RT into the Šúrsky kanál
4.200 – 4.700 through ORL soil absorption
15.200 – 15.600 through ORL and RT into the Podhájsky creek
15.600 – 16.500 through ORL and RT into the Mariansky creek
16.500 – 16.770 up to the Highway D4 section of Záhorská Bystrica – Devínska
Nová Ves
Proposed relocations and road changes:
- Relocation of the field road (under D4 at 3.765km), category P 6/40, overall length of the
relocation is approx. 680 m
- The road II/502 modification at the FOI Rača is an enlargement of the existing four-lane,
directionally divided road by adding joining and turning lanes to the intersection. The length
is 1.477 km.
- Relocation of the field road (at the crossing of FOI Rača), categ. P 6/40, estimated relocation
length is 1.200 km
- Relocation of the field road at 14.500 km of D4 on the right, categ. P 6/40, 707 m long
- Relocation of the field road (over the west portal of the Karpaty tunnel at 15.179 km of the
D4 highway), categ. P 6/40, 270 m long
- Relocation of the field road (under D4 at 15.775km), categ. P 6/40, overall length of 270m
15
- Construction of a walking and cycling path (at 16.559km of D4 highway) at the crossing of
Záhorská Bystrica, 5m wide and 253m long
Access roads and construction yards:
During the D4 construction, the construction mechanisms will be provided access to the
constructions site, mainly to the large objects construction sites (Karpaty tunnel, bridges and
interchanges). In principle, it is expected that all public roads will be used as main access routes
to get direct access to the construction site, while prospective suppliers of works will keep on
moving along the D4 route, along the surfaces of the permanent land use of the structure.
The relocation of the1.2km long field road will be used to access the east portal of the Karpaty
tunnel and it will be connected to the existing field road in the vineyards, concurrent with the
II/502 road. The relocation of the field road at km 14.500 of the D4 highway, which is 707m
long, and the highway D4 route will be used to access the west portal of the Karpaty tunnel.
The access road to the above-ground part of the ventilation shaft runs from the Bratislava
municipality of Rača along a forest road around Pieskový creek, under the Biely kríž hill, then
by Štefánikova magistrála road south-west for approx. 2 km, and then in direction west by an
unpaved forest road up to the shaft itself.
Construction yards at the FOI Čierna voda, FOI Rača and FOI Záhorská Bystrica premises, also
at both portals of the Karpaty tunnel.
Karpaty tunnel - variants 2a, 2b, 7a, 7b, 7c
The tunnel, formed by two tubes, south and north, will be operated in a one-way basic mode.
Both tunnel tubes are divided into sections built by tunnel boring and the bored sections built in
open construction pit at both portals, which will subsequently be buried.
The lengths of the sections and the total lengths of the tunnel tubes are shown in the table below.
Tunnel section Variant 2a Variant 2b Variant 7a
Variants 7b and
7c
Excavated tunnel at the west portal 50 993 50 550
Bored tunnel 7,992 8,042 9,850 9,900
Excavated tunnel at the east portal 20 20 50 50
TOTAL 8,062 9,055 9,950 10,500
Based on the total length of 8 to 10.5 km (according to the specific variant) the tunnel is
classified as long (length > 3,000 m) under STN 73 7507, by which several aspects of its
technical solution are determined.
The vertical conduct of both tunnel tubes of the Karpaty tunnel is mostly defined by the
longitudinal gradient in the amount of 0.60 % in the ascent in direction of the west portal. In
proximity of the west portal, there is a vertical break and the route descends towards to portal in
a 3.0% slope. The height arc at the west portal has a radius of 20 km.
Technical solution of tunnel structures
Excavated tunnels at the east portal
Excavated tunnels will be built in an open building pit, using shotcrete and bolts. The
construction of the tunnel tubes shall be made of reinforced concrete, designed with membrane
waterproofing. After the construction of the tunnel tubes and the front portal wall, the space of
the pit will be filled with the material excavated from the tunnel up the original ground level.
Excavated tunnels at the west portal - variants 2a, 7a
16
The excavated tunnels, 50 m long, shall be built in an open building pit, using shotcrete and
bolts.
The construction of the tunnel tubes shall be made of reinforced concrete, using the designed
waterproofing membrane. After the construction of the tunnel tubes and the front portal wall, the
space of the pit will be filled with the material excavated from the tunnel up the original ground
level.
Excavated tunnels at the west portal - variants 2b, 7b - prolonged
The excavated tunnels 550 m long (700 m), shall be built in an open building pit, using shotcrete
and bolts. The construction of the tunnel tubes shall be made of reinforced concrete, designed
with membrane waterproofing. After the construction of the tunnel tubes, the space of the pit will
be filled with the material excavated from the tunnel up the original ground level. Model cross-
section of the excavated tunnel is included in the Feasibility and Effectiveness Study.
Bored Karpaty tunnel - tunnel construction and cross profile
The cross-section of bored tunnels is circular, depending on the proposed construction
technology of boring using the full-profile boring machinery TBM. The vertical axis of the road
is equal to the tunnel profile axis. The cross-section is designed so that it complies with the
current regulations, mainly STN 73 7507. The resulting designed internal cross-section of the
construction of the bored tunnel consist of a circumference with a semi-diameter of 5.35 m at the
intrados of the tunnel lining. With the expected tunnel lining composition, it represents a
diameter of TBM 11.7 m. Model cross-sections of the tunnel are included in the Feasibility and
Effectiveness Study. Ventilation
The tunnel will be ventilated by a forced-air ventilation system (cross ventilation). The exhausts
shall be located both at the portals and the ventilation shafts. The variants 2a, 2b, 7a, 7b, and 7c
use one ventilation shaft.
The solution of the tunnel ventilation in individual variants:
Variant 2a - the section spanning from the tunnel beginning at 6.213 km up to 8.137 km shall be
ventilated by the portal exhaust, the section between 8.137 km and 12.168 km shall be ventilated
by the central exhaust located at approx. 10.060 km, the section between 12.168 km and the end
of the tunnel at 14.275 km shall be ventilated by the second portal exhaust.
Variant 2b - the section spanning from the tunnel beginning at 6.213 km up to 8.137 km shall be
ventilated by the portal exhaust, the section between 8.137 km and 12.675 km shall be ventilated
by the central exhaust located at approx. 10.060 km, the section between 12.675 km and the end
of the tunnel at 15.268 km shall be ventilated by the second portal exhaust.
Variant 7a - the section spanning from the tunnel beginning at 4.7 km up to 7.640 km shall be
ventilated by the portal exhaust, the section between 7.640 km and 12.615 km shall be ventilated
by the central exhaust located at approx. 10.580 km, the section between 12.615 km and the end
of the tunnel at 14.650 km shall be ventilated by the second portal exhaust.
Variant 7b, 7c - the section starting at the beginning of the tunnel at 4.7 km up to 7.640 km shall
be ventilated by the portal exhaust, the section between 7.640 km and 12.890 km shall be
ventilated by the central exhaust located at approx. 10.580 km, the section between 12.890 km
and the end of the tunnel at 15.200 km shall be ventilated by the second portal exhaust. In
variants 7b and 7c the tunnels are identical, so are the ventilation sections.
Tunnel construction procedure
In the first stage of the tunnel tubes boring, a parallel construction of both portal building pits is
expected, both east and west, including their clearance and static securing. In front of the
excavated areas at both the east and west portals, there shall be zones reserved for the building
sites related to the tunnel tubes construction.
The tunnel tubes of the Karpaty tunnel will be bored by two TBMs from the side of one of the
17
portals. The other portal boring will be conventional (NATM). Escape routes shall be bored after
the tunnel tubes are built. Shafts and ventilation connections shall be bored along with the tunnel
construction.
Vajnory tunnel - variants 2b, 7b
The tunnel coverage, 700 m long, consists of two partly separated tunnel tubes in the section
from 0.9 km to 1.6 km of the D4, which shall be in operation in a one-way basic mode. Based on
the total length of 700 m, the tunnel is classified as medium (length < 3,000 m) under STN 73
7507, from which several aspects of its technical solution will derive.
Vertical conduct of both tunnel tubes is defined by a longitudinal gradient in the amount of 0.91
% in the descent from the east portal and a gradient in the amount of 1.29% in the ascent towards
the west portal. The vertical curve in the centre of the tunnel reaches a radius of 20 km. The
tunnel is lead in a directional circular curve with a 1.570 km semi-diameter and partly also in the
transition curve.
The construction of the tunnel coverage is composed of the lower part, the reinforced concrete
pit forming the base construction and of the upper part - the coverage itself. The upper part of
the construction lining is formed by bearing ribs of reinforced concrete and pillars of the central
section. The space between the ribs is filled by transparent materials allowing natural light in.
Over the central section, there are openings allowing natural ventilation of the transport space of
the coverage.
The construction technology supposes building a underlying construction - a reinforced concrete
pit, under the protection of the bracing and insulating constructions. Then, the vertical and
horizontal bearing constructions of the coverage will be built.
Technological equipment of the tunnel provides its operational and security functions.
Considering that the tunnel coverage is not a tunnel as defined by STN 73 7507 and
in TP04/2006 ("hanging wall" over the tunnel is interrupted by ventilation openings), its
equipment is appropriately modified, compared to the tunnel of the same length category.
Brief technical and technological description of the construction - variant Senec - Pezinok -
Lozorno (SPL)
The highway D4 route begins with the FOI Chorvátsky Grob on the highway D1, almost in the
middle between the existing FOI Senec and the planned FOI Triblavina. It runs on in direction
Pezinok on a low embankment, reaching maximum height of 5 m, or in a 2 m deep cut. At 2.615
km the highway is crossed by a bridge on a field road relocation. At 5.450 km the highway
crossed the relocation of the road III/5023 by an underpass (the bridge on the road relocation).
In the section between Slovenský Grob and Viničné, the highway turning left becomes
concurrent with the planned relocation of the road II/502, which is connected to the FOI Pezinok.
At this interchange, the highway crosses by a bridge the Viničiansky creek twice and the
Mahulianka kanál once.
At 8.233 km, it crosses the Stará Blatiná kanál by a bridge. Starting from the 8.5 km, the vertical
alignment of the highway keeps rising up to a 12 m height embankment, at 9.732 km it crosses
the road II/502 relocation by a bridge at the height of 12 m above the ground level.
The highway D4 route runs on west on the same embankment, at 10.321 km it crosses both the
railway No. 120 Bratislava – Žilina and the existing road II/502 by a bridge . Over the bridge, it
continues on the embankment reaching 6 m. Before the east portal of the Karpaty tunnel at 10.7
km, the highway passes into a 9 m deep cut.
The total length of the Karpaty tunnel is 12.4 km, according to this variant. The tunnel is
equipped with 2 ventilation shafts. The shaft is located at 14.313 km. The exhaust is accessible
by a paved forest road coming from the town of Svätý Jur, approx 2.5 km west from the built-up
area edge. The shaft is located at 19.094 km. Its exhaust is also accessible by a paved forest road,
connecting Lozorno, Borinka and the adjoining cottage area.
18
At 23.450 km, in the section between the west portal of the Karpaty tunnel (at 23.1 km) and the
east portal of the Karpaty tunnel (at 23.6 km), the highway D4 crosses a valley with a small
water stream by a bridge.
The total length of the Katušiná tunnel is 1.850 km. Its west portal is located at 25.450 km. From
the wast portal of the Katušiná tunnel on, the highway D4 route continues slightly above the
existing terrain (an embankment of maximum height of 5 m), and runs directly to the existing
interchange of the FOI Lozorno (D4 over D2), behind which this variant ends. At 27.068 km, the
highway underpasses the bridge on the relocation of the road II/501 by a new route.
The total length of this variant is 28.065 km, the width arrangement of the highway D4 is
designed in the category D 26.5/120 and 2T 8.0/80 in the Karpaty and Katušiná tunnels
respectively.
Proposed interchanges:
- highway FOI Chorvátsky Grob, interchange of tubular shape at 0.000 km of the highway
D4, including also an adjustment of the highway D1,
- highway FOI Pezinok, tubular interchange with a feeder into the relocation of the road
II/502 at 6.853 km of the highway D4,
- highway FOI Lozorno, clover leaf shaped interchange at 27.691 km of the highway D4,
including also an adjustment of the existing highway D2 at the interchange branches
Proposed bridges:
Outline of the variant SPL bridges:
Bridges over D4 - 6 (length of the bridges - 59 m, 59 m, 95 m, 59 m, 310 m, 71 m)
Bridges over D4 - 5 (length of the bridges - 71 m, 23 m, 92 m, 45 m, 71 m)
Bridges on an interchange branch - 1 (length of the bridge - 71 m)
Bridges on the road I/2 - 1 (length of the bridge - 71 m)
Bridges over railway - 1 (length of the bridge - 71 m)
Bridges together: - 13 (total length - 1,073 m)
Proposed tunnels:
In the variant SPL the proposed Karpaty tunnel is 12.4 km long, while the Katušiná tunnel is
1.850 km long. Their further specification follow.
Highway sewerage system: The Feasibility Study did not include a sewerage solution for this variant, therefore, in view of the accessible documentation and field survey, as recommended recipients shall be used the Rakytov creek and Matejkov kanál at the Lozorno interchange, alternatively a part of the sewerage system shall be
mouthed into the highawy D2 sewerage system. A left-sided nameless tributary of the Suchý potok
shall be used as a recipient in the section between the portals. It is possible to drain the east
section into the kanáls of Šúr, Viničniansky, Stará Blatiná, Mlynský potok and a nameless kanál
at the FOI Chorvátsky Grob. Considering the capacity of the mentioned watercourses and the
nature of the terrain, it is probable that the construction of retention basins shall be necessary.
Proposed relocations and road changes:
- Relocation of the road III/5023 (over the highway D4 at 5.450 km), category C7.5/60,
length of relocation approx. 737 m
- Relocation of the road III/5022 (over the highway D4 at 8.513 km), category C7.5/60,
length of relocation approx. 425 m
- Relocation of the road II/501 (over the highway D4 at 27.068 km), category C9.5/70, length
of relocation approx. 993 m
- Relocation of the road I/2 (to the left part of the highway D4 at 27.700 km), which crosses
the road III/0237 at a circular intersection at 2.015 km, category C 9.5/70, the relocation
length is approx. 2.771 km
19
- Relocation of the road III/0237 (continuation of the variant D4 at km 28.065), with
arrangement changes from D 26.5 to C9.5/80 up to the circular intersection with the road I/2
and continues in category C 7.5/60, total relocation length is estimated to 1.072 km
- Feeder of the relocation II/502 at the interchange FOI Pezinok (right from the highway D4 at
6.853 km), category C11.5/80, total length of the feeder is 1.545 km
- Relocation of the field road (over the D4 highway at 2.615 km), category P 4/30, approx.
425 m long
Access roads and construction yards:
Within the construction of the D4 highway it will be necessary to provide access of construction
machinery to the construction sites, especially to construction sites related to large objects, such
as bridges, intersections, etc.. In principle, it is expected that all public roads will be used as
main access routes to get the direct access to the construction site, while prospective suppliers of
works will keep on moving along the route, along the surfaces of the permanent land use of the
structure. In some parts, the site will be divided by means of obstacles surmountable with
difficulty or at high cost.
Some tertiary roads belonging to different entities can be used as access routes to the
construction site. The condition of these roads typically requires treatment (repairs of the road
cover, construction of a new road, extending the road, etc.).
Indicative plan of temporary tertiary roads construction:
- access road to the D4 building site - access from the road III/5022 continuing along a field
road to the highway, length of the adjustment of approx. 530 m,
- access road to the D4 building site - access from the road III/5023 continuing along a field
road to the highway, length of the adjustment of approx. 2300 m,
- access road to the D4 building site - access from the road II/501 in the urban area of the
Lozorno municipality, continuing along a field road to the highway. The length of the
adjustment of approx. 1200 m.
The envisaged access road treatments are indicative, further processing of the documentation
will provide further analyses of the issue and it will especially be negotiated with the relevant
processedities and organizations.
Construction yards are probably going to be located at the tunnel portals and in the area of the
FOI Chorvátsky Grob, FOI Pezinok, and FOI Lozorno.
Karpaty tunnel and Katušiná tunnel - variant SPL
The Karpaty tunnel in SPL variant is formed by two tubes, south and north, which will be
operated in a one-way basic mode. Both tunnel tubes are divided into sections built by tunnel
boring and excavated sections built in open building pits at both portals, which will subsequently
be buried.
The lengths of the sections and total lengths of the tunnel tubes are shown in the table below. (in
metres) Tunnel section North tunnel tube South tunnel tube
Excavated tunnel at the west portal 40 60
Bored tunnel 12,300 12,300
Excavated tunnel at the east portal 60 40
TOTAL 12,400 12,400
Based on the total length of 12,400 m, the tunnel under STN 73 7507 is classified as long (length > 3,000 m), from which several aspects of its technical solution will derive. The Katušiná tunnel is also formed by two tubes, south and north, which will be operated in a
one-way basic mode. Both tunnel tubes are divided into sections built by tunnel boring and
excavated sections built in open building pits at both portals.
The lengths of the sections and total lengths of the tunnel tubes are shown in the table below. (in
metres) Tunnel section North tunnel tube South tunnel tube
20
Excavated tunnel at the west portal 50 50
Bored tunnel 1,700 1,700
Excavated tunnel at the east portal 100 100
TOTAL 1,850 1,850
Based on the total length of 1850 m, the tunnel under STN 73 7507 is classified as medium (length < 3,000 m), from which several aspects of its technical solution willderive. Vertical conduct of both tunnel tubes of the Karpaty tunnel is defined by the longitudinal
gradient in the amount of 0.87 % in the ascent in direction of the west portal. The height arc at
the west portal has a radius of 10 km.
Vertical conduct of the Katušiná tunnel is almost entirely in vertical curve. The tunnel descent
amounts to 3.15% at the west portal.
According to STN 73 7507 the passage cross-section is designed for the width category 2T8.0.
Technical solution of tunnel structures
Excavated tunnels at the west and east portals - the Karpaty tunnel and Katušiná tunnel
Excavated tunnels will be built in an open building pit, using shotcrete and bolts for bracing. The
construction of the excavated tunnel tubes shall be consist of reinforced concrete, using the
designed waterproofing membrane. After the construction of the excavated tunnel tubes and the
front portal wall, the space of the pit will be filled up the original ground level with the material
excavated from the tunnel. The model cross-profile of the excavated tunnel is the same as in
variants 2 and 7.
Bored Karpaty tunnel - tunnel construction and cross profile
The cross-section of bored tunnels is circular, depending on the proposed construction
technology of boring using the full-profile boring machinery TBM. The vertical axes of the road
is equal to the tunnel profile axis. The cross-section is designed so that it complies with the
applicable regulations, mainly STN 73 7507. The resulting designed internal cross-section of the
construction of the bored tunnels consists of a circumference with a semi-diameter of 5.35 m at
the intrados of the tunnel lining. Considering the expected composition of the lining, it represents
a diameter of TBM 11.7 m.
Bored Katušiná tunnel - tunnel construction and cross profile
Given the length of the Katušiná tunnel, the conventional boring using NATM is taken into
consideration. The boring shall begin from one of the portals. Due to the proposed construction
technology, the cross-section of the bored tunnel is not circular. The vertical axes of the road is
equal to the tunnel profile axis. The cross-section is designed so that it complies with the
applicable regulations, mainly STN 73 7507.
Model cross-sections of the excavated tunnel are included in the Feasibility and Effectiveness
Study.
Ventilation
The Karpaty tunnel will be ventilated by a forced-air ventilation system (transverse ventilation).
Exhausts shall be located both at the portals and the ventilation shafts. Two ventilation shafts are
being considered. The proposed design includes 2 portal and 2 central exhausts in the tunnel. The
section spanning from the tunnel beginning at 10.7 km up to 12.507 km shall be ventilated by the
portal exhaust, the section between 12.507 km and 16.705 km shall be ventilated by the central
exhaust located at 14.313 km, the section between 16.705 km and 21.099 km shall be ventilated
by the second central exhaust located at 19.094 km, and the section between 21.099 km and the
end of the tunnel at 23.1 km shall be ventilated by the second portal exhaust.
The Katušiná tunnel shall have a longitudinal ventilation system, in view of the length of the
tunnel < 3000 m and the one-way traffic in both tubes.
Tunnel Karpaty construction procedure
For the beginning phase of the tunnel tubes boring, a parallel construction of both portal
construction pits is supposed, at both east and west, including clearance and static securing. In
front of the excavated areas at both east and west portals, there shall be zones reserved for the
21
construction sites.
The tunnel tubes of the Karpaty tunnel will be bored by two TBMs from the side of one of the
portals. The other portal boring will be conventional (NATM). Escape routes shall be bored after
the tunnel tubes are built. Shafts and ventilation connections shall be bored along with the tunnel
construction.
Tunnel Katušiná construction procedure
In the first stage of the tunnel tubes boring, a parallel construction of building pits at both, east
and west, portals is expected, including their clearance and static securing. In front of the
excavated areas at both east and west portals, there shall be zones reserved for the construction
sites.
The tunnel tubes will be bored conventionally (NATM) from both portals. Escape routes shall be
bored after the tunnel tubes are built.
Overview of the tunnel lengths in all the proposed variants 2a, 2b, 7a, 7b, 7c, SPL: Excavated and bored sections together
Variant
2a
Variant
2b
Variant
7a
Variants
7b and 7c
SPL variant.
Tunnels
together
TOTAL (m) 8,062 9,055 9,950 10,500 14,250
7. Total costs
Total indicative costs of the proposed variants according to the Feasibility Study (year 2010):
Assessment Report on the impact of " Diaľnica D4 Ivanka north - Záhorská Bystrica“ (Highway
D4 Ivanka North - Záhorská Bystrica) (hereinafter referred to only as Assessment Report) was
elaborated in view of the evaluation scope and the annex No. 11 of the Act No. 26/2006 Coll. on
the Environmental Impact Assessment amending and supplementing other acts as amended
(hereinafter referred to as the Act). The Assessment Report was elaborated by the HBH projekt
ltd., in December 2010, and the team leader was Mgr. Tomáš Šikula.
The Assessment Report was preceded by the evaluation of the Proposal „Diaľnica D4 Bratislava,
križovatka Ivanka north - Stupava“ (Highway D4 Bratislava - interchange Ivanka North -
Stupava) and the issue of the scope of assessment. The scope of assessment of the activity was
issued by the Ministry of Environment of the Slovak Republic, pursuant to the Article 30, under
the Act, on July 18, 2008, with the file number 7155/08-3.4/ml.
2. Distribution and Publishing of the Assessment Report
The Claimant submitted the Assessment Report according to Article 31 (4) of the Act, to the
Ministry on ................ According to the Article 33 (1) of the Act, after checking the necessary
requisites, the Ministry distributed the Assessment Report to
to all subjects involved
to general public involved. The Assessment Report was published pursuant to the Article 34 of the Act in a usual way at the relevant municipal offices, the Bratislava municipal office, and the internet page of the Bratislava municipality as
well as of the Ministry of Environment of the Slovak Republic (www.enviroportal.sk).
Park and Malé Karpaty SPA) in our region due to the inappropriate location of the highway
exhaust vent, raising the amount of emissions near them. The argument that the values are below
the limit will not stand because these limits are not determined for valuable areas and for any
increase in air pollution. Rather they are calculated for more burdened “urban” environments and
human health. Options affecting protected areas were also identified in documentation: changes
97
in air quality characteristics in the area, images of habitats, changes in the hydrological regime of
the area for Homolský Karpaty SCI, while for Malé Karpaty SPA it concerns a set of appropriate
habitats, noise and light interference, clashes with vehicles, the aquatic environment becoming
contaminated by water seeping from the road into bodies of water (p. 21 Impact Assessment of
Sites Community Importance and Special Protection Areas. Species sensitive to pollution and
deteriorating conditions can react immediately to their absence, even though the documentation
states that the impact is negligible. Beech vegetation growing in the area can accordingly be
disturbed (by acidification, eutrophication), in addition to the food chain, insects, pollinators,
bats, birds and others. A serious risk to human health is likewise the level of NOx, CO and also
solid particulate matter (PM), hydrocarbons along with other pollutants contained in the air
which were not mentioned in the documentation. It is expected for some substances that
minimum levels in the air will cause health annoyances despite limits having been set in the laws
of different countries. Very small particulate concentrations in air that is breathed have resulted
in health damage, and we ask for appropriate protective means to be employed at airways to
minimise the discharge of flue gases into the atmosphere (with scrubbers or active filters) and to
add this condition to project documentation (and to measures in the drawing - Fig. 2 Diffusion
Study and the like.). Likewise, guard tunnel ventilation shafts so as, .to prevent animals from
becoming injured as a consequence of being sucked into the ventilator (especially birds and
bats). Ventilation shafts should be constructed to reduce noise load in the area surrounding them
to the minimum level. These requirements are essential.
5) Air pollution tables relating to Borinka are missing from the dispersion study. We request
addition of conditions before (baseline option) and as the situation changes (variants).
6) Fig. 33 and 34 of Graphic Attachment No. 8 is an illustrative photo of Branisko which
displays an exhaust vent with access road. No map was found in the report documentation where
the access road to the exhaust vent will be from Highway D4 and what the road’s nature is. The
road from Rača to Biely kríž and to Červený kríž are mentioned. Where exactly will the access
road be situated? There is an existing "forest" road with a paved surface, or will it be reinforced
with asphalt for this purpose? We seek clarification.
7) For the sake of environmental protection and regional development, we are requesting an
overlapping highway in the entire sections along the built up area of Vajnory, along the Šúr NPR
protected area, under the interchange before Stupava and also extension of the overlapping
highway past the interchange. We are asking for a covered highway (at least partially) at
Marianka and at Ramsar locations to allow for a natural transition and for the lives of inhabitants
and animals, while minimising the adverse impact on nature and the landscape at longer sections,
such as is proposed in the report, meaning Option 2b, which is traversable for us, for 15
kilometres. We ask for noise barriers to be designed with portals on both sides of the D4 from
the massif and in parts not tunnelled.
8) The assessment report does not discuss the impact of light pollution from the central exhaust
vent on the mountain ridge (including the area surrounding access roads to the exhaust vent), and
neither does it do so for the highway itself outside the tunnel. It mentions light interference in
Chapter 11.3.4. of the attached Impact Assessment on the Site of Community Importance and
Special Protection Area.
Physicians worldwide are seriously concerned about the increased risk of cancer from night
light, and it can be quite significant. Cells are protected from tumours by melatonin - the most
effective antioxidant and one the body creates only in the dark. Sleep is a basis for good health,
and in the case of high intensity external lighting caused by light pollution melatonin formation
disorders occur that result in insomnia and other related health problems. It is shown that rare
and endangered species have disappeared from nature in cities as well as more common species
which are dependent on natural night darkness (or the frequency of such species have greatly
diminished). This is especially true for reptiles, amphibians and insects. Some zoologists believe
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that light traps significantly contribute to the impoverishment of species diversity in insects. The
loss of insects is so far a burning concern only of enthusiastic entomologists, but there has been a
greater response to the mass death of birds. Light sources directed at the sky especially disorient
those species that migrate at night, with fewer and fewer of them completing their journeys. A
Canadian expert on this issue, M. Mesure, estimates the number of birds that fly into lighted
buildings to be a hundred million a year. Inappropriate night lighting so disrupts night
ecosystems and confuses migrating birds, something currently not desirable in Borinka and
vicinity where there are birds, insects, bats and other animals living in declared protected areas
(SPA, SCI and national categories). We present a simple solution which we ask be incorporated
in the documentation for establishing conditions when the highway is constructed. The solution
is to install lamps with flat bottom covers so they sign under each other.
9) At a session of the Slovak Government, material not included was found by us, namely
Progress on connecting the Druzhba Pipeline with Schwechat Refinery (BSP Pipeline) and
fulfilment of the Memorandum of Understanding and Cooperation in Energy between the
Ministry of Economy of the Slovak Republic and the Ministry of Economy and Labour of
Austria, where a drawing mentions the probable tunnel as one possible option for routing the
pipeline. Building the D4 Highway D4 in a tunnel may pave the way for such similar proposals,
which would use the prepared corridor for other purposes, too, which is not desirable for
sensitive areas of the Carpathians. Also for this reason we believe that the impact on the cave
system and the impact on groundwater and the change in how it flows in the rock subsoil have
not been adequately evaluated in our view. Linked to it is the possible impact on the hydric
nature of the area (and just in the area north in the ridge) as also presented in page 35 of the
attached Impact Assessment on the Site of Community Importance and Special Protection Area.
Relevant analysis is missing which we seek to have added. In our opinion, the scope of the
assessment is not complete with regard to hydrogeological characteristics and surveys which
need to be completed and assessed. The area surrounding Borinka is known to specialists and the
general public for its vast cave system. It is possible that anthropogenic impact (vibrations from
excavation, traffic, the route itself on the rock subsoil, activities of groups of people in the last
decade against which security measures have been taken) and the earth’s natural activity
(earthquakes, landslides, tectonic faults, washouts) near Borinka are disturbing the rock
environment, hydrology and water saturation of the strata. The documentation (e.g. on p. 18 of
Impact Assessment on the Site of Community Importance and Special Protection Area.)
mentions a more marked impact and risks from tunnelling in fault zones, and in the crystalline or
Mesozoic strata and in the thrust zone of crystalline strata, due to the drainage of groundwater
linked to collectors of opened fault zones. The documentation does not sufficiently describe how
this element is going to be addressed. And what is proposed after the end of the structure’s useful
life, which is 30 years? We seek clarification. The Borinka cadastral district (massif on the side
of the mountain opposite where the tunnel is proposed) contains significant sources of drinking
water, which supplies not only the village of Borinka. Sources of drinking water will remain in
future a very important factor in decision-making with the general lack of this natural resource.
10) Do we believe, based on the points earlier mentioned in our opinion, that there has been
fulfilment of certain specific conditions defined in the scope of assessment (Conditions 2, 3
about the purpose; Point 5 - no compensatory measures have been proposed for either the
population or the biota; Point 6 - no visibility analysis has been prepared and no underlying
documentation has been provided for us to create it ourselves; Point 8 - measures have been
insufficiently proposed to eliminate the impact and an “umbrella“ measure is missing which we
have sought together with the village of Borinka to have included in the study phase in the
follow-up to different reports on the assessment and parcelling of the entire circuit, and “green
passageways for large animals” along the route of the entire D4; Point 9 - otherwise
incomprehensible; Point 10 - to propose measures to minimise; Point 14, 20 and 24 about
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changes in hydrological ratios and the cave systems - poorly executed; Points 15 and 25 -
Borinka is missing; Points 18 and 26 - comments are above, compensatory measures missing;
Point 19 - where are the data mentioned in the aforesaid study? And there are still more). Not all
substantiated comments to the study are arranged in the relevant chapters of the assessment
report. The mentioned comments we seek to develop and have included in the next process of
assessing environmental impact . Especially, the chapter discussing compensatory measures has
to be included. This might for organisms be the creation of a certain element in the Territorial
System of Ecological Stability (ÚSES) or revitalisation of disturbed habitat, and for the region’s
population it might be, for example, the construction of bicycle trails, creation of a small park or
rest facilities for tourists, modifying open space, and the like. We ask for proposal of such or
similar measures.
Based on the above, we prefer the baseline option.
In the case of completing the D4 , we believe the SPL option should be considered and there is a
need also to assess the Lamač - Krasňany option. If a tunnel is going to be driven and completed
between Borinka and Marianka, we are inclined toward Option 2b with modifications to improve
it. The other options in our view are entirely unacceptable and we disagree with their
implementation.
We continue to be committed to participating in the environmental impact assessment process
related to the Highway D4 ring road.
Malé Karpaty CA (letter from 20 May 2011) The Malé Karpaty civic association was registered at the MI SR on 8 October 2010 as a non-profit organization
bringing together people who strive to realize the objectives of the association referred to in the articles of the
association. One of the aims of the association is to protect the environment in connection with the planned
implementation of the D4 highway section through the Little Carpathians, an assessed activity under Act No.
24/2006 Coll. on Environmental Impact Assessment and its subsequent regulations. In accordance with the Act on
Environmental Impact Assessment, we hereby submit an application for inclusion of the Malé Karpaty C.A. among
stakeholders interested in the environmental decision-making procedures and inclusion among the parties in the
proceedings.
The position of the civic association was also supported by 362 citizens with their signatures. Signature sheets are
attached to this statement.
For clarity, our statement is divided into the following parts:
General society-wide comments
Specific comments from the perspective of the Marianka and Vajnory residents
Comments on the report in terms of processing the requirements specified in the scope of assessment number:
7155/08 - 3.4/ml dated 18 July 2008
A) General society-wide comments
The scope of the assessment addressed specific requirements for the administration range, as well as the assessment
of the new option solution. The assessment report did not meet the scope of the assessment specified under No.
7155/08 - 3.4/ml dated 18 July 2008 in several points, and the assessment of expected impacts is not full and
comprehensive in accordance with Par. 3 of the NC SR No. 24/2006 Coll. In our opinion, the processing quality of
the submitted EIA does not correspond to the range of the largest investment of its kind in the region, and the
importance of the impact of construction on the environment.
For a greater overview and clarity of our statement and our objections to the report, we have chosen the form of
comments written individually for specific points of the scope of assessment.
Objections to the preparation process of the proposed D4 highway:
According to Paragraph 6 of NC SR Act No.24/2006 Coll., if several proposed activities are in the operational or
spatial context, their common assessment can be performed. The D4 highway in the section from Jarovce to the
section in Devínska Nová Ves was divided into four separate sections that have been taken out of context and
examined separately since 2001. The assessment process of the adjacent sections did not involve all affected
municipalities, which influenced the route and caused non-compliance with the requirements of residents on
health and quality environment in their place of residence. The right to a healthy environment is enshrined in the
Constitution of the Slovak Republic. The routing in the Stupava south intersection over the I/2 road also affected
the route of the following section in the cadastral area of the Marianka municipality, which was assessed
separately and where the residents demanded undersurface routing (in the sense under the current ground). The
same happened also on the east side, where the elevated crossing of the D4 with the D1 made it impossible to
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address the request of the Bratislava-Vajnory city district regarding the recessed D4 option near the Šúrsky
Kanál. The first section on the entire route of the D4 highway to be assessed was the DNV U/505 intersection of
the D4 - the Stupava south intersection, which in turn lead the predestined routing to the west and the east
without directly contacting the affected municipalities in these follow-up sections.
The construction purpose defined in the assessment report is unclear and contradictory. The purpose of the
construction in Chapter A/ll/2 mentions the relief of Bratislava from freight transport. When defining the criteria
for the selection of options in Chapter C.V., in particular, the impossibility of further urbanization in the area is
stated and stressed. We consider these contradictions as extremely important, because they do not only call into
question the very purpose of the construction, because the criteria due to which the construction is planned are
not clear, but also the criteria for the selection of the option.
The assessed SPL option has a planned traffic volume of about 12,500 vehicles, and in Options 2 and 7
Marianka-Vajnory, it is 25,000 vehicles. As confirmed by Ing. Jurkovic from Dopravoprojekt, a.s., at the public
hearing in Lozorno on 12 May 2011, the difference in the intensity of transport is due to the increase in urban
transport in Options 2 and 7 (Marianka-Vajnory), which are closer to Bratislava. This means that a share of over
50% on the total estimated traffic volume will consist of urban and not primarily transit traffic, which is the main
declared purpose. In Appendix 1, the Traffic Analysis, the distribution of urban and transit transport is
completely absent. The representative of the designer Ing. Jurkovič was not able to provide evidence of the share
of urban and transit traffic either at the public hearing of the Town Council of the Capital City on 10 May 2011,
or in Lozorno on 12 May 2011.
One of the arguments for the selection of the option was also the rounding of the transport by the D4 highway.
Such an argument regarding the interdependence of the sections has no traffic-engineering justification. The
transport semi-circle running in the zoning plan of Bratislava, with an outlet in Lamač, and on the other side in
the wider city centre, addresses the servicing of urban midtown areas more effectively within passenger
transport, while the D4 mainly addresses freight transport and its diversion outside the city, as stated in the
construction purpose. As demonstrated below, the diversion of freight transport is not efficient enough either,
and after launching the investment it will not relieve the northwest of freight. The transport corridors linking the
D1 and D2 motorways through the Krasňany - Lamač tunnel were not included in the assessment of the options
without justification either. This section is included in the current land-use planning documentations and the
Marianka municipality demanded its assessment still at the stage of intention. Given that this is an investment
financed from public finances, we request the finalization of the environmental impact assessment for this route
as well before the issue of the final opinion. This is to ensure optimal and economically the most promising
solution for the upcoming road.
Currently, the Regional Transport General of the Bratislava Self-Governing Region, which will comprehensively
evaluate the traffic in this region, is being procured. The EIA process for road construction should logically
follow after the processing of the general plan and analyzing the traffic needs and priorities of the region.
The negotiation and processing of the connection of towns and municipalities in the Bratislava region to the D1
through collectors (at the DUR stage) is currently taking place. Specifically, the D1-Bratislava-Trnava section,
six lane + collectors, is currently being addressed. The justification of the D4 is also questionable due to the
realization of these objectives.
The selection of the zero circuit corridor for the city of Bratislava was determined under different socio-
economic conditions - as prospective, still in the old land-use plan, valid with changes from 1976 to 2007. Its
location does not respect the intensive development of towns and municipalities near Bratislava in recent years,
or the new general social situation created by the opening of borders and accession of Slovakia to the Schengen
space. The route was originally proposed as an expressway, not as a highway. The original proposal of the city
on the development concept of the Slovak highway network was translated into the MTCRD SR's strategic
documents without sufficient analysis.
B) Specific comments from the perspective of the Marianka Vajnory residents
From the perspective of the Marianka residents:
The recommended undersurface routing option (Option 7c, whereby the location of the portal is at 15.5 km) does not
address the significant negative impact of noise on a large part of the Marianka municipality. The main road is only
300 m away from the highway route (in some cases - at the cooperative, it is approaching up to a distance of about
100 m). For this reason, we require the following when implementing the assessed intent:
1) shifting the route of the proposed highway away from Marianka, towards Stupava.
The highway route runs partly on the surface, and partly the body of the highway leans against a hill. Before the
portal in Option 7c) in the section from 15.0 km to 15.3 km, it crosses the whole hill massif. A few dozen meters
further, it runs through the entire length of the valley, without obstacles to overcome. All Marianka residents
logically expected the highway's route at the lowest point of the valley - as it was also shown in the video
presentation of the route from 2007. By shifting the route, costs on earth works would be saved, among other things,
since the route in Option 7c) passes at 15.0 km to 15.3 km through the hill massif, where the load will need to be
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released.
2) In case of failure in implementing Point 1, we require an undersurface route of the highway underneath the
intersection before Stupava, and reduce the entire highway route by 11 m, i.e. undersurface running in the entire
section - on the west side of the portal.
If the design of the intersection before Stupava does not enable this, we require re-assessing this intersection so that
the D4 highway is running below the intersection, not over it. According to our estimates, it is possible to lower the
highway route by 5 m even in the case of the elevated highway (part of the highway route in the section from 16.6
km to 15.8 km with opposite inclination). Underfloor highway running would reduce the highway route by about 11
m and enable the undersurface highway running throughout the required section.
We have no information that Marianka was invited to meetings on the location of the intersection as an affected
municipality. Responsibility for the current inadequate technical solution is therefore not borne by the Marianka
municipality. In terms of the EIA and in terms of the building act, it was necessary to invite all the municipalities
that may be affected by the construction as the parties, which resulted from connection of the individual D4 sections.
The law has been significantly breached by not inviting the Marianka municipality to the negotiations. The current
solution of the intersection at the highest point of the terrain and, moreover, with the above-surface routing of the
highway, is the worst possible solution from Marianka's perspective. The terrain is lower closer to Stupava, plus the
entire highway route would be behind the hill, which would naturally protect it against noise pollution. Also, there
would be less impact on the landscape scenery. See Appendix - Fig. 1.
3) In the event that the structure's altimetry is not adjusted according to the preceding Point 2, we require an
extension of the "undersurface" highway routing under Option 7c) to 16,500 km. The undersurface highway routing
is a very important element, not only in terms of protecting the population against noise and grime, but also in terms
of maintaining the recreational nature of the area - intensively used by people of Bratislava, but also the wider area.
Otherwise, the inhabitants of the Marianka municipality cannot agree with any of the assessed options. Marianka is
the most famous pilgrimage site in Slovakia, with a high visitation rate, with frequent biking trails, hiking trails and
the like. In the event of an elevated routing, the quality of life will significantly worsen and the recreational function
of the area will be significantly restricted. The mentioned impacts will have a very negative effect on the further
development of the municipality to which hundreds of families have moved in recent years with the prospect of
quiet, rural housing, and in many cases invested their life savings, or went into debt. Environmental degradation will
also reduce the property values in the area.
4) We request the execution of the final technical solution's visualization, including compensatory measures in terms
of urban settlements in Marianka - specifically from Karpatska Street, from the co-operative, from Vineyards, from
the highest point of Ovsisko Hill and the access road to Marianka.
5) We request that the construction in the D4 Ivanka-north - Stupava section starts only after the completion of the
connection of D4 to D1 on the east side. In order to protect people and nature during construction, we request
priority construction of the section from kilometre 15 to 16.7 (the recessed area behind the western portal) in order
to restore migration paths as quickly as possible and achieve protection from the noise, dust and emissions already
in the tunnel construction phase. This corridor would also serve for transport during the construction of the tunnel
and it would not bring public access roads to the municipality and inside Marianka itself. We request limiting the
completion time of this section to a minimum rate, up to a maximum of 1 year.
6) We disagree with the use of the quarry in Marianka as the repository of excavated rock from the construction.
The quarry is now a protected deposit area. Many bird species are nesting in the older quarries. Traffic volume for
the purpose of the earth exports would be unbearable for the transport network in Marianka.
7) We require that the highway surface be made of asphalt, maximally reducing the noise from rolling vehicles. This
was not considered in the EIA.
From the perspective of the Vajnory residents:
1) The recommended Option 7c) the design of an earth wall at a height of 11 - 8- 3 m creates a barrier for the
movement of people into the Šúr Natural Reserve, prevents migration and the interconnection of biocentres. Option
7 c) fails to sufficiently address the impact of noise and emissions on the environment, does not address the impact
on the recreational environment, cycling routes, and so on. In the event that the investment plan is implemented in
route 7 c) despite all the objections, we request anti-noise walls throughout the route, building an interconnection for
cyclists and pedestrians to the Šúr NR and to the vineyards. We also ask to examine the flyover option of this route
at this stage.
2) We request to start building part of assessed section II: Ivanka north - Stupava, from the Ivanka north intersection
to the Rača intersection after the construction of the Karpaty tunnel.
C) Comments on the report in terms of processing the requirements specified in the scope of assessment number:
7155/08 - 3.4/ml dated 18 July 2008
A number of specific requirements were determined in the scope of the assessment, including the assessment of the
new option solution on the Senec- Pezinok- Lozorno route.
The requirement to an option solution: For a further, more detailed assessment of the impact of the proposed activity
"the D4 Bratislava Highway, Ivanka north - Stupava intersection", a new corridor leading more north from the
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options on the Pezinok, Senec, Lozorno route, proposed in the intent, was also designed.
The condition was not met, the report assessing another route: Chorvátsky Grob, Svätý Jur, Lozorno. The route
selection of the assessed option was not justified in any way and its position in the region does not nearly come
close to the Senec-Pezinok-Lozorno route in the report referred to as the SPL option. The connection of section II of
the D4 behind VAJNORY, right after in Bratislava, will be an additional burden on the already overloaded D1
highway section between Bratislava and Trnava. With an interconnection further north we can expect to relieve
traffic on the D1 before entering Bratislava, because there would be the natural rerouting of, in particular, lorries
between the logistics transit centres of Trnava, Senec, Lozorno, and Malacky.
Comments on Point 2 in the scope: Give reasons for the purpose of construction from the social-wide view in detail,
its justification, and attach traffic forecasts for the given corridor.
Regarding Point 3 in the scope: Determine how large a territory the highway should serve, and complement the
detailed long-term transport studies of highway traffic in the SR, the linking of the SR regions, connections to routes
abroad and connections of Bratislava.
The reason for the purpose of the construction is incomplete and unsubstantiated by traffic surveys. The
assessment report defines the purpose of the construction as follows: "The construction of the D4 highway, whose
integral part is the Section II assessed by us (in six options) around the capital city of Bratislava, will significantly
help to solve the problem of transit traffic, as well as the problem of the insufficient road network capacity of the
capital. The benefit is primarily the diversion of transit traffic bound for the Czech Republic, Austria and Hungary.
It will greatly facilitate the transport operators of the affected area and relieve the neighbouring municipalities
from transit traffic, which should primarily be served by the highway network." However, when assessing and
selecting the option, the elaborated did not substantiate the society-wide significance of the D4 Ivanka-Stupava
section, because even in the transport development calculations for 2040, the assumptions come out to about
20,000 vehicles that would use the route per day, but not those currently in transit through Bratislava, as evidenced
by the transit traffic prognosis on the Lafranconi bridge.
Transit traffic on the Lafranconi Bridge, according to the elaborated's data, reached 69,631 vehicles/24 hrs in
2008, of which 12.3% was the proportion of freight transport. On p. 22 of the Transport-Engineering Documents,
it is stated that in 2020, after implementing the construction, transit traffic will represent 64,589 vehicles/24 hrs, of
which 16.26% will be other vehicles, including trucks. This means that the delay passage of passenger and freight
transport will lead to a collapse on the Lafranconi Bridge after the completion of the D4 highway. Section II of the
D4 highway should mainly address transit freight and its diversion outside of Bratislava. According to the traffic
analysis, the highest calculations regarding the utilization of the northern section of the D4 are projected to 756
lorries a day, increased further by 368 lorries per day currently using the Pezinská Baba mountain pass.
Contrary to the primary purpose of the construction, the report itself states the unfavourable regional traffic
situation as the main and only argument, the option did not follow the primary purpose that the highway network
should serve for.
The regional transport general of the Bratislava Self-Governing Region, which is to comprehensively assess the
traffic in this region, is currently being procured. The report's elaborated did not have sufficient evidence to choose
the optimal path for solving regional transport, and therefore the claim that the D4 will help the transport operators
in the affected area is not founded at all. We required supplementing the report with conclusions arising from the
transport of the BSGR Transport General.
Due to the fact that the projection of applicable land use plans of municipalities and towns in the affected area was
not made, the report incompletely defines the existing territory. The elaborated did not incorporate the transport
corridors planned in these land-use planning documents into their analysis either. For example, a connection on the
D1 at the upcoming Triblavina intersection is planned in the local land use plans of the Chorvátsky Grob
municipality. Furthermore, we highlight the already above-mentioned connection of towns and municipalities in
the Bratislava region via collectors, whose implementation puts the justification of D4 into question.
Comments on Point 4 in the scope: Quantify the analyzed environmental impacts of each option via a multi-criteria
evaluation.
The summary evaluation of the effects of the selected Option 7c) on the environment and population in
comparison with the 0-th state (without a highway construction) seems to be targeted and unsubstantiated by
factual data in several evaluated criteria.
The numerical summary of multi-criteria analysis is prepared based on partial assessments and conclusions for
each assessed area. The resulting comparison is behind the seven-digit scale whose criteria are not clarified in the
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individual impacts. Moreover, we do not consider the used data interpretation correct in certain cases. Specifically,
for example, regarding the effects on the population (p. 133, chapter C.III.1 states that "the implementation of
options....will reduce the negative impacts on residents, not only in the directly affected area, where the options are
routed so as to avoid settlements, but most especially in the surroundings, where the intention will contribute to a
significant improvement in the traffic situation in the entire city of Bratislava and the improvement of living
conditions for the inhabitants"... As a standard, the impact on the population is assessed according to the exposure
to noise, emissions/pollutants and dust during construction with regard to the population right around the
considered line structures, and not just in terms of traffic conditions for Bratislava and its wider surroundings...
The traffic situation is evaluated separately in the Transport System/Transport Benefits section (tab. C.V.2).
The developed complementary studies have unequivocally shown:
- in the case of noise, the necessity of the construction of noise barriers within the realization of the project both in
the Vajnory and Marianka areas, as the noise load will increase over the allowable concentration limits in the
external environment under the current legislation
- in the case of air pollution, the increase in concentrations of pollutants in a residential area compared to the 0-th
option, in the areas of:
Marianka and Vajnory-east in all monitored pollutants (i.e. CO, N02 (1 hr. and year)
in the areas of Stupava and Záhorská Bystrica and Čierna Voda in indicators CO (8-hr.), N02 (1hr.)... etc. (listed in
tab. 27 in dispersion study).
- the reduction of pollutant concentrations has been significantly demonstrated (in all monitored indicators) only in
the Rača and Svätý Jur-south locations.
It is therefore unclear how the "Report" elaborated came to the use of numerical quantification -5 for the impact on
the population in the 0-th option (i.e. substantially negative impact) and a neutral impact (0) for the selected option
7c??...
At the given stage of the EIA, a specific assessment of individual impacts on the selected components of the
environment and the population groups in the individual affected villages is needed. The presented EIA does not
adequately contain this. The impact on air is assessed globally for each option without division into sections, or
municipalities, in which the impacts are different (in positive and negative meaning) as provided by a separate
appendix (dispersion study). Therefore, the comparison of options is not objective, as described on p. 141. We
cannot therefore agree either with the quantification for the air area (-3at 0-th state, i.e. negative impact and a
slightly positive impact (+1) for the selected option 7c, which practically applies only to the Rača and Svätý Jur-
south areas).
The EIA even lacks surveys clearly defined in the scope of assessment, without which it is impossible to assess
specific impacts on geological environment, the impact on the stability of the rock mass and soil, the impact on
groundwater, karst, hydrological regime, and therefore it is also impossible to properly and objectively quantify
them numerically...
It does not contain specific compensatory measures assessing their impact on improving the situation (e.g. in the
area of noise protection, and it does not provide their visualization from several residential areas of the Marianka
and Vajnory municipalities). Instead, the EIA refers to other additional work at a later stage, but it is not specified
in detail within the aspect of time. Their results, however, can greatly influence the technical and economic
solution of the entire construction, which also plays an important role in the selection of an optimal solution.
A serious shortcoming within the evaluation is the lack of noise impact of individual options compared to the 0-th
status. We require supplementing the impact of noise on the population based on a new noise study under current
legislation, separately in the phases of construction and operation.
In the case of impacts on the country, we disagree with the assessment of the impact as "of little importance" - (p.
184- chapter C.III.18, or -1, a slightly negative impact (Tab. C.V.2) for the given technical solution - in Marianka
the highway is contemplated on an embankment with a height of 6m in the vicinity of residential areas; in
Vajnory, an embankment with a height of 3-11 meters. With the estimated noise barriers with a height of about 2-3
m it will be a new component in the country scenery with an overall height of 9-14 m.
This chapter, which is a summary assessment and at the same time the basis for the selection of the optimal option,
lacks the division of impacts for the construction phase and separately for the operating stage, which are
standardly used in the methodology - we therefore request adding an assessment of all impacts separately for the
field of construction and operation.
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For these reasons, we believe that the processing quality of the submitted EIA does not correspond with the scope
of the largest investment of its kind in the region and the importance of the construction's impact on the
environment and population.
Comments on Point 1 in the scope: In the assessment report, ensure a high level of environmental protection and
contribute to the integration of environmental aspects into the preparation of the options with a view to promoting
sustainable development in line with the European Sustainable Development Strategy (EU SDS) and NATURA
2000.
Regarding Point 5 in the scope: Assess which of the proposed options best reflect the principles of sustainable
development, with the lowest direct or indirect impact on the environment, including impacts on health, flora, fauna,
the reduction of biodiversity, soil, climate, air, water, landscape, natural sites, material assets, cultural heritage and
the interaction of these factors, and propose compensatory measures to reduce negative impacts.
Regarding Point 6 in the scope: Evaluate the impact of the proposed activity on the character of the landscape,
scenery, preserved natural territory on the west side and Carpathian vineyard landscape on the east side, with a
proposal of compensatory measures to eliminate or significantly reduce the negative impacts. Draw up
visualizations of individual options from the points defined by the affected municipalities, or other parties. Draw up
a visibility analysis (graphically and in writing) and supplement a situational sketch with a scale or describing the
distances of the nearest residential areas from the highway. Complement the visualization of the tunnel air outlet,
portals, construction yards and construction traffic routes.
We consider the report to be incomplete in addressing the requirements defined in related Points 1, 5, 6. In the
Vajnory site it does not deal with the impairment of property of inhabitants in the Nemecká dolina-Koncové area
and the "under the cooperative" area in the Marianka municipality. The impact assessment of construction on the
residents of Vajnory and Marianka, on their health and welfare, and the added stress of an enclosed space which
the territory is getting into by being surrounded by major transportation projects is also omitted, in the case of
Vajnory by the loss of the Šúr NR recreational facility and part of the vineyards. The highway is located on the
route of the supra-regional wildlife corridor connecting the Little Carpathians with the flow of the Little Danube. It
undermines the integrity of the system of the protected areas, interferes with the internationally protected habitats
and in combination with other investment plans in the region (Cepit technology park in Vajnory, the construction
in Chorvátsky Grob and Svätý Jur) it seriously endangers the sustainability of these areas. In such a case, the work
may be allowed only be based on imperative reasons of overriding public interest relating to public health, public
safety, or the beneficial consequences of fundamental importance for the environment, or if it relates to other
imperative reasons of overriding public interest based on the statement of the European Commission. Given the
above, we require supplementing the assessment of other options before the issue of an expert opinion regarding
the Assessment Report (the Krasňany - Lamač tunnel, northern connection of D1 and D2), and demonstrating the
urgency of the reason for overriding public interest.
Marianka is the oldest pilgrimage site in Slovakia and the first Marian pilgrimage place in the entire Kingdom of
Hungary. The construction will cause the liquidation of the chapel from 1608, which is registered in the list of
monuments of the Marianka municipality. In addition, it is typical for a high visitation rate of tourists, frequent
biking trails, hiking trails and beautiful nature. The report did not adequately deal with the impact of construction
on the Vrchná hora area, which is being prepared for a declaration as a protected area. It is also missing in the
inventory of flora in this area.
In the Graphic Appendix 9 - visualization of individual options, the most needed views of the highway from the
closest residential houses in Marianka and in Vajnory are absent. Similarly, the selected Option 7c is not shown in
a close situation in the case of Marianka. Only Option 7a is shown in a detailed situation in Figure 17. Therefore,
we require finalizing the following detailed visualizations (even with the proposed compensatory measures-noise
barriers), namely:
- from the level of the current terrain from the nearest residential buildings (specifically, Karpatská Street from the
co-operative, from the Vineyards, from the highest point of Ovsisko Hill and from the access road to Marianka, so
that the residents of residential areas are informed on the altitude routing of the highway and its landscape
embodiment with the surrounding nature
- visualizations from the E-W view (from the Carpathian massif, from the western portal to the Stupava-south
intersection)
- visualizations from the Stupava - Marianka field road, which is used for recreational purposes
- likewise we require finalizing this visualization for residential areas in Vajnory
• Further we request supplementing the visualizations of air shafts from the tunnel and the portals, and further
specifying the position of building yards and traffic routes.
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The comments to the point 9 of the scope: To analyse the impact of the proposed activity on other planned use of the
territory. To assess the impact of the individual variants on the social and economical development of the concerned
villages, in particular the restriction of the recreational utilisation of the concerned territory for winter and summer
tourism and sports (jogging, running, cross-country skiing, cycling, trekking, etc.) and the prepared project "The
Green Lungs of Bratislava" and the development of Vajnory, with the proposal of the compensatory measures. To
the point 11 of the scope: To assess the impact of the barrier effect of the proposed activity on the possibility of
passages for agricultural machinery, passengers and cyclists in the concerned territory. To assess the impact of the
proposed activity on the existing and planned cycloroutes.
The requirement is insufficiently assessed and elaborated. The proposed compensatory measures are rather of a
symbolic character. No ecoducts and alternate logic interconnection with the NPR Šúr is designed. The report
states less significant impact on fauna, flora and habitats, the landscape, climate, CHKO, which does not
correspond with the fact the highway route is located in the route of the supra-regional corridor of the Lesser
Carpathians - the Little Danube River NRBK 23 leading in parallel with the water courses of the Little Danube
River and Šúr kanál.
The elaborated did not deal with the prepared Lesser Carpathian and Šúr cycling cross road interconnecting
Vajnory and Šúr kanál dam, that continues to the city of Svätý Jur and the village of Ivanka pri Dunaji. On the
place of the planned GSI Rača, it passes above the railway to the vineyards and from that place to Bratislava.
The section between the Ivanka North - Rača intersections is used for jogging, skating, tourism and daily type of
recreation. We required to add the report by the analysis of the activities in the territory and the subsequent
serious proposal of the compensatory measures.
Also in the Western part, the construction of the highway would lead to the impairment of the recreational zone
between Stupava and Marianka, nowadays used as cycloroute.
The comments to the point 10 of the scope: To assess the barrier effect of the individual variants for the restriction
of the movement of migrating animal species, with the analysis of the impact of the restriction of the migration on
the reduction of the number of individuals in the individual populations (state the counts of the individuals of the
populations of individual migrating species) and the potential reduction of biodiversity and to propose the measures
for the minimisation of the impact.
The construction of D4 in the proposed variants creates another important barrier for animal migration that is
nowadays rather fragmented in population by the highway D2 as well as the much-frequented state roads. Even
now it often comes to the killing of game on the main road between Záhorská Bystrica and Lamač, in the way of
the natural bio-corridor. The sunken design would eliminate this undesirable phenomenon. The highway route
shall create another barrier on the Western side (Marianka) in the new West-East direction, as an addition to
already existing barrier in the North-South direction (the route I/2 Záhorská Bystrica - Stupava), namely at the
forest boundary, where the migration of animals is the most intense.
The comments to the point 13 of the scope: to assess the impacts on environment during the construction while
stating the duration of construction, with an informative specification of transport routes for construction and the
working regime. The transport routes for the construction should not load the contemporary transport
communications.
We consider the requirement to be insufficiently met, since the report states they would use all the existing
public communication during the construction. The report considers the storage of surplus excavation material
also alternatively in the existing old quarries in the wider proximity (in particular, they state the quarry in
Marianka - p.m27, Chapter B.I.3, just one possible access road in Marianka would be used for that purpose
(Karpatská street). However, the impact of the activity on the inhabitants was not assessed in details, yet we
may suppose that the impact on the given infrastructure and the inhabitants would be catastrophic.
The comments to the point 15 of the scope: To earmark the concerned territory from the point of view of the impacts
and the effects on inhabitants.
The insufficient meeting of the requirements of the assessment scope. The person elaborating the report mentions
the need of further additional studies in the case of noise, he/she plans to propose the particular compensatory
measures only on the basis of them. However, they must be presented within the given EIA stage already. In
addition, we require to up-date the projection of the built-up area of the residential zone in present time, as well as
the projection of the intended built-up area pursuant to the planning scheme of the villages (Marianka, Vajnory) for
the considered intention in details, using the scale of 1:5 000.
The comments to the point 16 of the scope: State the informative areas, where they plan to establish the construction
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yards, dump sites and through what places the access roads should lead to them. State, where construction yards
may not be established.
To the point 17 of the scope: Describe in detail the disposal of excavated soil. State the variants of transportation
and the specification of the location where the excavated soil from the tunnel would be stored.
With regards to the mentioned alternative of storing the earth and rock material in the quarry near Marianka (p.
27) we warn that:
- a quarry is the protected deposit territory,
- reclamation is possible only after the approval of the project by all involved authorities
- reclamation must be the subject of expression of all citizens
- reclamation does not automatically mean to cover it with dead rock
- many bird species nest in older quarries
- the inhabitants of Marianka do not agree with the sheet coverage of the quarry and concentrated traffic of lorries
through the village.
The comments to the point 18 of the scope: To elaborate the noise study and dissipation study for the period during
the construction and during the operation, for day-time and night hours, to compare the obtained data with "zero"
condition and to propose the compensatory measures on this basis. To the point 26 of the scope: To state the
production of exhalates from the tunnel duct located in the mountain range and the impact of exhalates on the
surrounding nature and vineyards. To propose the compensatory measures. To the point 27 of the scope: To assess
the noise load of nature by central tunnel duct.
The comments to the noise study:
It is not clear from the presented material, what way, method was user or on the basis of what they determined the
intensities on the individual roads and the assessed highway D4.
We require to re-process the given assessment of the impact of the construction on noise load in the concerned
surroundings according to the requirements of the legislation in force in the Slovak Republic, as well as in
accordance with the procedures and method used in both the Slovak Republic and abroad for similar assessments
of impacts on environment.
a) The assessment of noise load caused by the assessed section of D4 is not carried out according to the
requirements of the Act No. 355/2007 Coll. on the protection, support and development of public health and on the
amendment and supplementation of some acts (as amended) and its implementing regulation regarding the
assessment of noise in external environment of the Regulation of the Ministry of Health of the Slovak Republic No.
549/2007 Coll. on allowable values of noise, infra-noise and vibrations and on the requirements for the
objectivisation of noise, infra-noise and vibrations (as amended). According to the mentioned legal regulations,
noise in external environment is assessed for all sources for time sections of day (6.00 a.m. - 6.00 p.m.), evening
6.00 p.m. - 10.00 p.m.) and night (10.00 p.m. - 06.00 a.m.) pursuant to the given legal regulations . In the entire
work, including annexes, the noise load is assessed just for the time sections of day and night, which is in a
fundamental disaccord with the requirements of the given law. In the tables of predicted values for local calculation
points, both day and evening are stated in brackets after the information of reference time interval for the individual
variants of design. The calculated value of the equivalent value of sound level A is however always stated just one
for every point, the assessed year and variant of design, which implies the elaborated supposes the value of
equivalent sound level A is identical for time interval of day and night. However, this does not correspond to the
reality. When presenting the area noise load (the Graphic Annexes), the calculation and the display of noise load for
evening are absolutely absent. The given fact is the principal breach of the requirements stipulated in the Act No.
355/2007 Coll. and the related law for the assessment of noise caused by road transport in external environment.
Withal the elaborated refers to the fact the assessment is made in accordance with the given law.
2) The assessment of noise load is made using a mathematical modelling while using the procedure "The
Amendment in the Methodology for Calculation of Noise from Road Transport" from the elaborated Liberko, M.,
published in journal edícia Planéta 2/2005, published by the Ministry of Environment of the Czech Republic.
Following the methodology is nt officially approved in the Slovak Republic for the calculation of noise spreading
out and the determination of area noise load from road traffic for the needs of the assessment of impact of noise
from road transport on health. The given procedure was not officially verified in the Slovak Republic and the values
obtained using the given procedure were not officially validated for any model situations. When using the given
procedure, it is necessary to use several non-.acoustic data and parameters when calculating noise load, the emission
value of the source of noise - road transport shall be calculated from them. In the case of their incorrect application,
misuse and incorrect selection of input data we would obtain the values of noise load that may significantly distort
the resulting data. Therefore the correct use of input parameters and data for the calculation is the decisive step for
the obtaining of reliable data. In particular when the used calculation procedure is not verified for the given model
situation by verification measurements, what is absolutely absent in the given work (the modelling and assessment
of "zero variant" without the implementation of the intention while considering just the existing roads enables such
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verification at minimum costs). The work also does not state what input data were used by the elaborated for
calculation. The work does not state any unambiguous input parameter on the basis of which it would be possible to
verify the correctness of calculation, to confirm the correctness of the applied procedure and methodology of
solution when determining the noise load in the surroundings of a road communication. The work states 24-hour
intensities of traffic and the share of cargo transport, but it does not state the 24-hour profile of transport distribution
(at least for statutory determined day sections) that is necessary for the calculation and determination of noise load
from road transport for the individual day sections pursuant to the law referred to by elaborated in the entire work.
The work does not state what wear course were considered in the calculations. The incorrect specification of the
parameter may cause the variance in calculation of 6 and more decibels. The work also does not state how the
change in the meteorological conditions (wind direction) may affect pre predicted results. The elaborated does not
deal with the impact of meteorological conditions on the predicted results of noise load in the presented report at all
. . Withal the direction and speed of wind may affect the value of noise lad by more than 3 decibels on the particular
place of assessment (as long as we consider the wind conditions in the area of Marianka - Stupava, as well as in the
surroundings of Vajnory). The work does not state what surface was considered in the proximity of the assessed
road and thus it is not clear what are the suppression parameters of the surroundings and the impact on the obtained
data in the concerned surroundings.
3) The work does not declare the model of the concerned territory is made on the basis of altimetry with accuracy of
1 meter, which is insufficient for the assessment of the construction of such importance and in the terrain with such
variable morphology, even when considering the embedding of the assessed road communication into the terrain) ..
The work does not clearly imply the authorisation of data out of which they created the three-dimensional model
used or the prediction of noise situation that would make the results "more reliable".
4) There is not stated at least approximate estimate of the number of inhabitants in the concerned surroundings in the
report for the individual variants of design, for whom the conditions for living would be deteriorated or improved
due to the construction of the given structure for the impact of an amended noise situation (e.g. versus the "zero
variant"). When assessing the impacts on environment, such information would fundamentally clarify the suitability
or unsuitability of the proposed design for the particular territory and the suitability or unsuitability of the proposed
measures for the reduction of the unfavourable impacts on environment in the concerned surroundings. No
projection of the valid planning scheme was made in Vajnory and even in the village of Marianka., where the
residential functionality approaches the highway as close as 100 m. The impact of noise was not assessed for the
locations at all.
5) On the basis of the given facts we may state that the presented "Noise Study" that deals with the assessment of
impact of the proposed highway D4 Bratislava Ivanka North -Stupava, is not elaborated in accordance with the
requirements stipulated by the law in force in the Slovak Republic (at the time of documentation elaboration and its
submission for further approvals). The selected procedure and methodology of the determination of supposed noise
load from the assessed road communication used in the work is not in accord with the common procedures applied
for the purposes of the assessment of impacts on environment in the Slovak Republic and abroad. The work does not
state the used input data for calculation, validation of the foreseen (predicted) data is not declared and the method
used for the creation of the model used for calculation is not specified.
Several defects mentioned here were commented in the construction intention stage already. It is the waste of
public means that the person elaborating the report used the methodology invalid in the Slovak Republic also for the
report stage.
Note: In the Slovak Republic, they approved the procedure for the prediction of noise load from roads using the
prediction with the application of mathematical modelling using the procedure described in the „OŽPaZ/5459/2005,
The Special Guide of the Public Health Service Authority of the Slovak Republic, amending the procedure for the
elaboration of strategic noise maps pursuant to the requirements of the Act No .2/2005 ll. as amended. The
procedure was verified by a quantity of verification measurements for various situations of the design of roads,
various surfaces, intensities and for various locations of roads.
6) The required assessment of impact of noise on nature by the central tunnel duct was not elaborated. We require to
complete it in the next stage.
7) We require to expand the noise monitoring spots in Vajnory to the location of Nemecká dolina Valley - Koncové.
The conditions for the dispersion study:
We present the principal objection to the location of the ventilation duct on the place of the Western portal..
According to the dispersion study, the duct with 8-metre chimney should serve for the diversion of products
from both tubes of the Western part of the tunnel. This regards approximately 2.5km section of a tunnel (the
remaining exhalates shall be diverted by the central and Eastern chimney). It is very inappropriate that this
significant source of immissions is planned on the location where the highway approaches the family houses of
the inhabitants of Marianka the most. At the same time, according to the statement of the representative of HBH,
they did not considered transport from Karpatská street - the main access communication from Marianka - at all.
(This shall similarly apply also to the side of Vajnory, where they state just the highway D1 in addition to the
existing sources). Therefore we ask to shift the duct in the alternative of the prolongation of the tunnel towards
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the intersection or in the Eastern direction, as far from the dwellings as possible, at least to the place where the
tunnel comes out from the mountain range to the surface. The location of the duct as far from the residential
zones as possible is required also for Vajnory.
We require to clarify in details the methodology of dissipation study since the consideration of prevailing wind
directions in the assessed territories (NW-SE to N-S) is not clear from the presented graphic outputs of
contaminant isolines. State what particular sources were taken into account by the study (the highway itself + the
static and mobile sources in the surroundings.) We require the study would comprise all 3 outlets from air
conditioning system (2 portal ones and a central one) in the given study within the highway assessment.
The report did not deal with the required impact of the imissions from portal duct at the East side towards the
vineyards and the contamination of grapes.
In the case of the assessment of the impact of emissions/imissions on inhabitants, we have several objections to
the used methodology of assessment, in particular within their overall quantification for the individual variants.
They are described in details in the comments in point 4.
We require to include all existing sources of noise and emissions in the dispersion and noise study, i.e. all
transport elements of road and railway network, there is also an airport in the surroundings of Vajnory... e.g. the
traffic from the main access road to Marianka and Vajnory is apparently missing. We also require to make the
assessment also on the territory with the planned and existing functionality of residential zone, incorporated in
the valid planning scheme.
The comments to the point 14 of the scope: To assess the impact of digging out the tunnel on water sources and
karst caves and to recommend the technologies for digging out that would minimise the negative impacts. To the
point 19 of the scope: To elaborate the detailed geological and hydrogeological survey with the assessment of the
impact of the proposed activity on surface water regime and ground water flow, in particular in the tunnel sections
and in Vajnory section.
To the point 20 of the scope: State the results of hydrogeological analyses of the changes in ground water flow due
to the implementation of the proposed activity.
To the point 21 of the scope: To state the analysis of the change in the height of ground water in the built-up
territory of Vajnory due to the proposed activity.
To the point 22 of the scope: To assess the functionality of the anti-flood protection of Vajnory in the case of the
implementation of the proposed activity.
To the point 23 of the scope: To assess the impact of vibrations from the proposed activity on the stability of the Šúr
kanál dam.
To the point 24 of the scope: To describe in detail the impact of the proposed activity on the rock environment and
the possible risk when digging out the tunnel on the basis of information from the IGHP.
The specific requirements of the Assessment Scope specified under numbers 14, 19-23 mutually regard the
geological and hydrogeological conditions, the impact on ground, surface waters, the method of taking away water
from road body and tunnel and indirectly thus also on the property of the inhabitants of Vajnory and Marianka, etc.
For this reason, we express ourselves to them in block.
Just geological and hydrogeological study was elaborated for the purposes of administration, it does not replace
the required detailed geological and hydrogeological survey. The requirement was not met to the required
extent. The results of detailed survey in the given geological environment may significantly affect the routing
itself , the technical design and thus also the financial costs of the proposed route.
The geological and hydrogeological characteristics are made very cursorily on the basis of the description of the
geological and hydrogeological units. The geological and hydrogeological characteristics should be assessed in
details in the given stage with regards to the complex natural conditions in the proximity of the projected
sections. The presented general characteristics does not specify the particular conditions on the route that may be
various with regards to the heterogeneity of geological environment and they may differ from the specified
characteristics. This fact has a great importance from the point of view that the route intersects various
geological and hydrogeological environments (Crystalline rock, Mesozoic, Neogene, Quaternary..,) In the case
of line structures, a detailed characteristics of environment in the individual km intervals is required, or in the
case of larger geological changes also with greater details - not only at the level of the statement of the general
hydrogeological units.
The person elaborating the report refers to the geological opinion (Geofos, 2010), however it is not the part of
the annexes to the Assessment Report. In addition, the drawing of the route - in longitudinal profile in the
geological map is absent here. We require to complement the given materials (map in the scale of 1:10 000).
The presented report does not include the quotation in the part on geological and hydrogeological conditions,
what significantly reduces its credibility.
From hydrogeological point of view it is important to assess also the vulnerability of rock environment (from
the point of view of stability and quality) as well as of ground and surface water from the point of view of
quality and quantity, which is absent in the report. Without this knowledge it is not possible to assess and select
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the optimum variant. Without the assessment of quality of ground and surface waters that shall be the final
recipient for waste water, it is not possible to objectively assess even the proposed method of sewerage system
of the road body, including the tunnel.
At Vajnory side, the report considers the cumulation of storm water from the highway D4 running to the
existing recipients, the Lysé Lake that is the regional bio-centre and to so called dry retention reservoir that shall
be created between the body of the highway D4 (from km 2.524 as far as km 3.600) and the right-bank dam of
Šúr kanál that would be able to accumulate ca 30,000 m3 of water. The person who elaborated the report stated
smaller terrain modifications and the installation of water facilities for pumping water shall suffice. The
proposals are not assessed from the point of view of economic ad operation costs and from the point of view of
the stability of Šúr kanál dam, which was constructed in 1941-1943 as an earth dam. We require to add the
economic costs of pumping of water and the stability of Šúr kanál dam. We require to complete the analysis of
the changes in the level of ground water in the built-up territory of Vajnory and Marianka due to the proposed
activity and to thoroughly assess the functionality of the anti-flood protection of Vajnory in the case of the
implementation of the proposed activity.
From the point of view of release of waste water to ground and surface waters, it shall be necessary to assess the
particular local hydraulic properties of environment within the assessment of the possibility of intended
infiltration, as well as the concrete flow-rate conditions in surface water courses in addition to the assessment of
quality. For example,in the section on water disposal from the road- p. 35, Chapter B. 11.2 they consider the
infiltration to subsoil and in the sections around Vajnory and Svätý Jur {the section of km 4.5-6.0), located in the
environment of proluvial and deluvial sediments (that have mainly the character of little permeable cohesive
sediments - clays, gravel clays in the surface levels to 3.0 m, in greater depths of 3.0-5.0 m also the character of
gravels, however rather loamy ones). Furthermore, the level of ground water is rather shallowly under the
surface, ca 2.0-3.0 m under the terrain which considerably restricts or even excludes the possibility of considered
infiltration...
The insufficient notion of the geological and hydrogeological conditions and the missing information on the
particular technical design (as from the road body itself, the tunnel and sewerage system) lead to the non-
objective assessment of the individual variants.
In the case of digging out the tunnel, it shall be necessary to consider also the potential tributary of ground
The particular impact on ground and surface waters shall subsequently condition also the demands for
monitoring system of ground and surface waters during and after the construction of the route.
The resulting comparison of the impacts of the individual variants on rock environment and ground and surface
water is very general and not well arranged, it is hiding behind a scape, the criteria and limit values of which are
not explained in details again.
We have not got and answer to the impact on hydrological regime of springs and karst waters. They did not
assess the impact on the spring of Vydrica Brook and the impact on the spring of the Saint Well in the village of
Marianka. Furthermore, the impact of the construction on the flow rate and the quality of the Rakový potok
Brook, the Fandlovský potok Brook and the Fofovský potok Brook that supply the NPR Šúr with water inflow,
furthermore the impact of the construction of the flow rate and quality of the Mariánsky potok Brook, the
Račiansky potok Brook, the Podhájsky potok Brook, the Strúha Brook and Šúr kanál that are considered to be
the final recipient when discharging waste water. Similarly, quality and hydraulic parameters of rock subsoil in
the considered sections of direct infiltration into the subsoil are not assessed in details. We require to supplement
the given information on the basis of results of geological survey works.
The report does not deal with the assessment of seismic and tectonic risks. The person elaborating the report
confirmed during the public discussion on12.5.2011 in Lozorno that they consider the overall ending of waste
water from the tunnel in Marianka. a The fact was not especially mentioned and assessed in the report . We
require to technically specify the given information in detail.
In addition to the above required surveys in the highway route (the geological and hydrogeological survey), we
recommend also the execution of geophysical survey - the assessment of seismic and tectonic risks.
According to the achieved results of the given surveys, it shall be necessary to propose and implement the
compensatory measures.
The comments to the points 29 of the scope: To introduce the map of ÚSES into the graphic annexes with the
location of regional and supra-regional bio-corridors.
To the point 30 of the scope: To introduce the projection of valid planning schemes of Bratislava, the municipal
parts of Bratislava and the affected villages into the graphic annexes.
The report does not comprises the individual annex of the elements of USES, what was indirectly proved also by
the person drawing up the report at the public discussion in Bratislava. The graphic annex 3 is not complete, it
lacks all the important elements of USES - in particular the supra-regional bio-corridor of NRBK 23 leading in
parallel with water courses of the Little Danube River and Šúr kanál, in the route of which the proposed highway
is located. We require to complete the assessment of the impact on the Territorial System of. Ecological Stability
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as the consequence of the restriction of the parameters of supra-regional bio-corridor due to the impact of highway
and to complete the map of´USES pursuant to the methodology valid in the Slovak Republic. The requirement in
point 29 was not thus met.
The requirement in point 30 was not met. The graphic annex 6 does not comprise the projection of valid planning
schemes of the city of Bratislava and its municipal parts, the city of Svätý Jur and the villages of Chorvátsky Grob
and Marianka. I consider this to be a principal defect. This implies also the incorrect conclusions of the report as
for the impact on health of the affected villages, the impact of noise on the development territory, the devaluation
of the property of citizens, etc. The report even does not deal with the planned transport routes of regional
importance, which distorts the conclusions of the zero design as well as the directional traffic load, for example
from Chorvátsky Grob through Vajnory to the city. Civil protection of the inhabitants of Vajnory is not completed
, nowadays the exit route towards the NPR Šúr is intended for them.
We require the projection of the built-up area of residential zone in the present time as well as the projection of the
considered built-up area pursuant to the planning scheme of the concerned villages (Marianka. Vajnory) to be
completed for the considered intention in details, using the scale of 1:5 000, as it was already mentioned in the
comments to point 15.
The comments to the point 36 of the scope: To assess the impacts of the highway on hunting regions in the
concerned territory.
The assessment of the impact on hunting regions states in Chapter C.III.16: "its significant division and
impairment of continuity", while the multi-criteria assessment state on contrary to the statement that the impact
on fauna, flora and habitats is without a significant intervention, which is a direct conflict.
The comments to the point 40 of the scope: To assess the impact of the highway on the Vrchná hora and Vajnorská
hora locations.
The person elaborating the report omitted the fact of the planned declaration of the protected area of Vrchná hora
and he/she did not assess the impact of the structure on the protected territory in detail, also the inventory of flora
is missing - there are rare plant species there.
Conclusion:
According to us, the presented report does not meet the whole range of statutory conditions. It does not justify the
already mentioned purpose of the construction itself, namely the diversion of transit transportation. It does not have
the sufficient conclusive and informative ability for the objective comparison of the assessed variants. It assessed the
impacts on environment and the inhabitants themselves in insufficient way. The part of the carried out assessment of
impact on inhabitants (the noise study) is not elaborated in accordance with the valid legislation, which is the
principal breach of the requirements stipulated in the Act No. 355/2007 and the related law for the assessment of
noise in external environment and thus it reduces its informative value.
It does not provide responses to many specific requirements stated in the assessment scope. Instead of this, the EIA
replaces the obligatory parts by expressions that the individual and particular impacts shall be finally dealt with in
the next stage by additional studies (e.g. the detailed geological and hydrogeological survey, the specification of
particular anti-noise measures). However, the achieved results in the given environment (the variability of
geological and hydrogeological conditions) shall affect the technical, time demandingness and thus directly also the
financial valuation of the given structure(the mining and excavation works, the taking away of waste water, potential
tributaries of ground, karst water, etc.)
The ambiguity of the particular geological and hydrogeological conditions and thus also the ambiguity of the impact
of the proposed technical solution on the selected components of environment (the rock environment, ground and
surface water from the point of view of quantity and quality) thus even does not allow the acceptance of the
presented economic costs of investments that may significantly differ from the given estimates.
The principal problem of the presented report is the insufficient description of the purpose of the structure and its
thorough traffic justification. Despite that the statement the tunnel should deal with the transit transportation (the
report states the transport should be routed to the Czech Republic and Hungary), they rather significantly argue by
the relief of a traffic situation in Bratislava, which is not supported by objective traffic analyses in the report. As
long as the objective of the investment is also the relief of traffic in Bratislava, it shall be necessary to equivalently
assess also the variant of Krasňany-Lamač route more to the South. The argument the variant represents the route of
a city communication shall not hold water. The route of Marianka - Vajnory variant is also the re-classified original
route of the city zero circuit to the highway one, approximately 6 years ago.
Annexes:
Fig. 1 - The possibility of the lowering of the highway route for Marianka
The paper with the signatures of citizens who agree with the standpoint of the civil association.
Dušan Statelov – Director of the Civil Association
Civic Association (further refered to as „OZ“) Malé Karpaty (letter dated 15.7.2011, supplement)
We supplement the following points to our statement on the submitted EIA. In case of contradiction, the supplement
replaces the statement.
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We request:
1) Return of EIA to the submitter for rewriting, or change of the elaborated (due to violation of the applicable laws).
2) Given the fact that the quality of the submitted EIA does not respond to the scale of the largest investment in the
region in terms of importance of the construction impact on the environment and population and does not take into
account comments raised in the long term by parties involved in the proceedings to this construction, we require
rewriting of the submitted EIA.
3) Taking into account comments from Marianka community to the EIA intention from 2008, as well as statements
from communities of Marianka and Borinka from 2007.
4) Inclusion of the option D4 Lamač – Vajnory route, proposed in comments to the EIA intention from 2008 (point
II.b), and also the Lamač – Vajnory route in the city semicircle route to the assessed options, as well as D4 Lamač –
Vajnory route interconnection with city semicircle Lamač – Krasňany route.
5) Clear justification of the purpose and the justness of the construction from the transport point of view. Indication
of the city and transit traffic proportion and freight and passenger transport proportion with using of toll system data.
Commented in the statement to the EIA Intention in 2008 (point II.a). D4 on the Austrian side joins the expressway
S8 and not the highway network.
6) In options of the route leading through Marianka, we require level arrangement change of D4 intersection with
the state road I /2 so that the highway D4 will be conducted bellow state road I/2 and not above as it is at present.
This will reduce the highway route by 11metres and enable under level conduction of the whole D4 highway section
in Marianka to the intersection. Section embedding was already required by Marianka community in 2008 in the
process of EIA Intention.
7) We reject options with the above level conduction of the highway on the mound! The given request was
mentioned in the statement of Marianka and Borinka communities as of 24.07.2007 as well as in the statement of
Marianka community to the EIA intention in 2008 (point II.b). Therefore, the argument of the project
documentation elaborated that it is currently not possible to change the project as the feeder and associated junction
construction is being completed, is unjustified. The project designer and investor had almost 4 years to finalize the
documentation for the given construction, in order to fulfil the request for “embedding of the highway in the
affected residential zone area” bellow the existing terrain.
8) Displacement of air pollutant exhausts to the state road I/2 intersection.
9) We require, for the section II. so-called D4 Ivanka-North – Stupava, to begin building solely after the completion of D4 to D1
connection on the east side.
10) In order to protect the population and the nature during the construction, we require preferential building of the section from
the portal to the min. 16,7 km, or to the intersection with the state road I/2 (embedded part beyond the west portal) in order to
restore the migratory routes and to obtain protection of the population from the noise, dust and emissions during the tunnel
building, as soon as possible. This corridor will serve the traffic during the tunnel building and will not burden public access
roads to the community and in the Marianka community itself. We require keeping the time for completion of this section to the
minimal extent and at maximum of 1 year.
11) We do not agree with postponing of our comments incorporation to the following stages of documentation. We require
incorporating all comments at this stage of EIA revision, not in the subsequent documentation stages, such as planning
permission, building permission.
Dušan Statelov – Civic Association Chairman.
NDS a.s., statement to the above mentioned OZ Malé Karpaty requirements (letter dated 16.8.2011)
OZ Malé Karpaty request:
1. Return of EIA to the submitter for redrafting, or change of the elaborated (due to violation of the
applicable laws)
NDS statement:
1. No applicable laws have been violated during the EIA process. Preparation and the assessment of the proposed
options of highway D4 Ivanka north – Záhorská Bystrica was guided by the current legislation, as it is in case of
other highway constructions. According to the Act No. 24/2006 Coll. of Laws on the assessment of the
environmental impact, the EIA Intention has been drawn, comments on it were – after a technical follow up on the
feasibility and effectiveness study – taken, assessed, evaluated in the EIA Report. If OZ Malé Karpaty has any
knowledge of law violation by the contractor, it should be stated. Change of the elaborated is unjustified. OZ Malé
Karpaty certainly observes the legislative framework for procurement under the Act No. 25/2006 Coll. of Laws on
public procurement. The successful tenderer is professionally qualified company as are its employees, who prepared
the Report on assessing the impacts on the environment.
2. Given the fact that the quality of the submitted EIA does not respond to the scale of the largest investment
in the region in terms of importance of the construction impact on the environment and population and does
not take into account comments raised in the long term by parties involved in the proceedings to this
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construction, we require redrafting of the submitted EIA
2. Quality of the submitted EIA report definitely corresponds to the quality of the largest road investment in the
region. If it was not so, the EIA Report would be returned to the Ministry of Environment of the Slovak republic
(further referred to as “MŽP SR”) for redrafting or completion within the statutory period, § 31, sec.3 of Act No.
24/2006 Coll. of Laws on the assessment of the environmental impact (not later than 7 days) since receiving of the
Report to MŽP SR. The Report was delivered to MŽP SR on 09.03.2011. The significance of the impact of
construction on the environment and the population was in detail assessed and evaluated in the EIA Report. Given
these (long term) comments on the EIA Intention, as indicated in the scope of assessment (furthermore referred to as
“RH”) – assessment of conducting of highway embedded under the terrain (Vajnory, Marianka), assessment
requirement of new option, etc. – it was not possible, following the Intention preparation to ensure the EIA Report,
since the EIA process (Intention and Report) addresses the impacts of future building on the environment and
assesses the sustainability of the technically designed work (in this case technically resolved options of the highway)
in the region.
Technical solutions are designed by project designers, technical experts, transport engineers, economists, etc., who
possess education and professional competence for this kind of work. The process of environmental impact
assessment is also evaluated by experts on the environment, the fauna and flora, etc. who also have education and
professional competence required for this kind of activity. As the comments set out in the scope of evaluation were
of technical nature, it was necessary to ensure and to technically resolve required height changes for conducting the
highway at Vajnory and in Marianka and also to technically design – NEW route through Carpathians in direction
Senec – Pezinok – Lozorno (SPL,. requested in RH.
All these technical “completions” were ensured by NDS according to Act no. 25/2006 Coll. of Laws on public
procurement, by invitation to tender for development of technical background – Study of the feasibility and
effectiveness of the D4 highway, in which reasonable requirements from the RH will be addressed. Company
Dopravoprojekt, a.s. Bratislava, which became the winner of the tender for the development of the Study of the
feasibility and effectiveness of the D4 highway, carried out the study in 2009.
Designed technical solution was the basis for EIA Report. In this specific section, it was for example solution for
highway embedding under the terrain in Marianka and in Vajnory – options 2b, 7b a 7c, tunnel extension in
Marianka, proposal of new route of passage of D4 through Carpathians (SPL option).
When the summary is done: EIA Report assessed ALL REASONABLE requirements raised by the participants of
the proceeding in the course of throughout preparation of D4 highway Ivanka north – Záhorská Bystrica and also
requirements set out in RH.
3. Taking into account comments from Marianka community to the EIA intention from 2008, as well as
statements from communities of Marianka and Borinka from 2007
3. Comment from Marianka community to the EIA Intention from 2008 was, extending of tunnel by portal overlay
in Marianka and of highway route at the mouth of the tunnel. The following conditions are fulfilled:
In option 2b, 7b and 7c is tunnel extension in Marianka by about 600 meters (to 15,200 km).
Highway route after the exit from the Carpathians tunnel is in the following continuation led in the kerf, i.e. 4 meters
UNDER terrain, in another continuation 2metres UNDER the terrain (in total length by about 380 meters). Western
portal of the tunnel is extended and the highway route IS at the mouth of the tunnel embedded under the terrain.
All these options were in the EIA report assessed and evaluated.
Borinka community has not agreed with the option 3, which was omitted from further consideration, therefore it was
not assessed in the EIA Report.
4. Inclusion of the option D4 Lamač – Vajnory route, proposed in comments to the EIA intention from 2008
(point II.b), and also the Lamač – Vajnory route in the city semicircle route to the assessed options, as well as
D4 Lamač – Vajnory route interconnection with city semicircle Lamač – Krasňany route.
4. Since 2008, it was explained at all meetings that the D4 highway is being solved in route of the zero circuit and
the city semi-circle with outlet in Lamač is building in the competence of the Magistrate of Capital City of Slovakia
– Bratislava and IS NOT subject to D4 highway solutions. The same applies to Lamač – Krasňany interconnection.
Each of the routes (D4 highway and the city semi-circle) is planned and prepared for different kind of transport. The
city semi-circle is the Magistrate of Capital City of Slovakia – Bratislava investment.
This requirement is not justified.
5. Clear justification of the purpose and the justness of the construction from the transport point of view.
Indication of the city and transit traffic proportion and freight and passenger transport proportion with
using of toll system data. Commented in the statement to the EIA Intention in 2008 (point II.a). D4 on the
Austrian side joins the expressway S8 and not the highway network.
5. Transport was drafted in detail in the Study of the feasibility and effectiveness as a separate part with regard to all
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activities in the region. Since this study was the technical basis for the EIA Report, the transport part was taken from
it.
The need for Bratislava bypass was considered as transport-justified construction.
The road network of the capital city of Bratislava is due to its location, expanse and development characterized by
high increase of traffic congestion. It is a fact that Bratislava is crossed by three multi-modal transport corridors
(corridor no. IV., V., VI.) and the Danube shipping corridor, which are source of the transit traffic.
Bratislava as the capital is the source as well as destination for car traffic. High congestion at the entries to the city is
also caused by extensive sub region called “Great Bratislava” from which high number of residents commutes to the
city for work, education and other activities. The resettlement trend of urban population to the countryside increases
this effect. Congestion across the city network to which transit traffic is often carried over is not conductive to the
continuous transport operation in the region.
D4 highway around the city will significantly help to solve the current transport problems. The contribution will be
mainly in diverting of the transit traffic in direction to Austria, Hungary and Czech Republic. It will also
significantly contribute to the operation of the affected area and unload the surrounding communities from the
transit traffic.
D4 highway will accumulate all kinds of transport i.e. transit, source, destination as well as inner city transport,
because it is conducted in the position of the cadastral boundary of the capital city Bratislava. The subsequent stages
of the project preparation (DÚR, DSP) will also include transport section, which will always update transport
information. Data in DÚR will be based on the 2010 census as well as the latest outcomes from the toll system.
While preparing the documentation for planning permission, building permit, the transport section will be updated
with regard to the results of the national traffic census in 2010, also taking into account other traffic data, for
example toll system.
Yes, the D4 highway on the Austrian side joins the expressway S8, which is part of the outer road ring around
Vienna. From the wider transport relations viewpoint, D4 highway connects Slovakia with highway networks and
expressways in Austria. With category arrangement of the Austrian expressway S8 is the same as our D4 highway
and that is category 26,5 / 120.
6. In options of the route leading through Marianka, we require level arrangement change of D4 intersection
with the state road I /2 so that the highway D4 will be conducted bellow state road I/2 and not above as it is at
present. This will reduce the highway route by 11metres and enable under level conduction of the whole D4
highway section in Marianka to the intersection. Section embedding was already required by Marianka
community in 2008 in the process of EIA Intention.
6. Height conducting of D4 highway at the Záhorská Bystrica intersection (D4 above the I/2 road) is given due to
the terrain conditions in the area since the beginning of the preparation of the entire D4 highway route. This height
conducting connects not only to the D4 Ivanka North – Záhorská Bystrica section, but also to the D4 Devínska Nová
Ves – state border Slovak Republic/ Austrian Republic section. D4 highway in Záhorská Bystrica – Devínska Nová
Ves section (known under the working title as Stupava South intersection) was handed over in half profile to the use
to motoring public on 01.08.2011.
While preparing the mentioned construction, which was handed over into operation, during the preparation the
concerned state and local authorities expressed their concerns to the height conduction of the highway above the
crossing road I/2, no comments were raised from the concerned subjects.
It is necessary to contact the Ministry of Transport, Construction and Regional Development of the Slovak Republic
(further referred to as „MDVRR SR”) with the request for change of D4 highway and I/2 road at the Záhorská
Bystrica intersection.
Its demolition and building of the new one in required height configuration could be from our point of view
considered as sabotage or obstruction of the financial funds from the state budget.
The requested change cannot be justified even by that this build up work is new solution that NDS “invented”
because as it is build it is in the urban plan of the Marianka community, the Magistrate of Capital City of Slovakia –
Bratislava and also higher territorial unit (further referred to as “VÚC) of Bratislava for at least 25 years.
Embedding of the highway route as requested by the Marianka community in 2008 to the EIA Intention is
incorporated in the EIA Report: at the exit of the highway from the tunnel portal in cadastral area of Marianka, the
D4 highway is in the 6 meters depth and in the further continuation the highway is in the 2 meters depth under the
terrain. On the terrain – on the mound it ascends only for the length of 150 meters, in order to cross the lane which is
in the ravine, without collision.
7. We reject options with the above level conduction of the highway on the mound! The given request was
mentioned in the statement of Marianka and Borinka communities as of 24.07.2007 as well as in the
statement of Marianka community to the EIA intention in 2008 (point II.b). Therefore, the argument of the
project documentation elaborated that it is currently not possible to change the project as the feeder and
associated junction construction is being completed, is unjustified. The project designer and investor had
almost 4 years to finalize the documentation for the given construction, in order to fulfil the request for
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“embedding of the highway in the affected residential zone area” bellow the existing terrain.
7. The EIA process requires assessing option solutions. It is the right of every concerned subject to incline towards
solution that suits them. By assessing of the options of the viability in the area from all points of view, the
elaborated suggests option which is best for the population and the environment. Requirements of the Marianka and
Borinka communities dated 24.5. 2007 were summarized into 8 points: NDS has responded to this letter on
4.6.2007. These were the main comments: Lamač-Rača tunnel requirement we explained in our answer, highway
omitting in Borinka area was fulfilled by RH issuance. Option 3, which crossed the Borinka cadastral area was not
in the assessment scope (issued by MŽP SR) required for further assessment, therefore in the EIA Report it was not
assessed. Tunnel portal extension by about 600 meters and its reduction under the terrain was fulfilled in the Study
of the feasibility and effectiveness and subsequently assessed in the EIA Report. In the statement, reduction by
2metres under the terrain is required and in the Report the highway options 7b and 7c are reduced at the tunnel exit
by 4 meters under the terrain. Passage for migratory animals is dealt with in the EIA Report (we attach copy of the
letter as of 24.05. 2007 and the NDS answer).
In the statement of the Marianka community from 2008, to the EIA Intention, point II.b), I quote: to add new option
resulting from option 7 on the east side, with under level conducting towards intersection with state road in Stupava.
In case D4 will not be conducted under level we will not agree with route location.
This requirement is considered in the Study of the feasibility and effectiveness by proposal and in the report about
assessing of embedded options (7b, 7c). We attach statement to the Intention from 2008.
Technical documentation designer did not say that change of the project at present is not possible. The designer said
that if sub amendment in the highway route conducting is made (for example little deeper embedding of the highway
under the terrain or highway sift) it is possible, but after documentation elaboration for planning permit, if it is
included in the conditions from the Concluding statement. He also said that when requiring change of Záhorská
Bystrica intersection level solutions (road I/2 above terrain and highway D4 on the terrain) it would be necessary to
demolish the whole Záhorská Bystrica intersection and to “lift” the I/2 road above the terrain and it would be
necessary to begin at Záhorská Bystrica petrol station and on the same length in direction to Bratislava. This
solution would have to be subsequently technically verified and approved by MDVRR SR Marianka community did
not have any comments to the territorial proceedings of this highway building (Stupava south intersection)in
individual preparation stages (granting planning permission and building permit) and to height solution , which is
today build up (road I /2 on the terrain and D4 highway above the terrain).
Construction of D4 highway Ivanka North - Záhorská Bystrica, and also D4 Záhorská Bystrica – Devínska Nová
Ves is PART of the whole D4 highway route, where individual buildings are connected with common intersections.
In this case Záhorská Bystrica intersection is common connection of Ivanka North – Záhorská Bystrica and
Záhorská Bystrica – Devínska Nová Ves.
Preparation of highway construction D4 Záhorská Bystrica – Devínska Nová Ves was prepared in advance, that is
why it is handed over to operation in half profile.
After elaboration of Intention of D4 highway Ivanka North – Záhorská Bystrica (Stupava) technical solution was
necessary for highway embedding under the terrain – according to Marianka community requirements. This was
solved in the Study of the feasibility and effectiveness, as already mentioned above. Therefore we have worked on it
for 4 years. To put the whole highway under the terrain (into tunnel) was requested at public discussion of EIA
Report.
8. Displacement of air pollutant exhausts to the state road I/2 intersection
8. I tis possible to put as comment for solution in documentation for urban planning
9. We require, for the section II. so-called D4 Ivanka-north – Stupava, to begin building solely after the completion of D4 to
D1 connection on the east side.
9. Construction of D4 highway Jarovce – Ivanka North connects to construction D4 highway Ivanka North – Záhorska Bystrica
in interception Ivanka North, which is interception for two motorways – D4 and D1.
Considering the traffic congestion caused by vehicle passing from the east direction right through Vajnory, town district Vajnory
requires to extend the construction of D4 highway Jarovce – Ivanka North to the „Rača“ intersection (crossing of the D4
highway with II/502 road).
According to the current plan of the investment preparation, the first construction to be realized will be D4 Jarovce – Ivanka
North (resp. Rača) and subsequently construction of Ivanka North (resp. Rača) – Záhorská Bystrica, after connection of D4 and
D1 motorways will already be done.
10. In order to protect the population and the nature during the construction, we require preferential building of the section
from the portal to the min. 16,7 km, or to the intersection with the state road I/2 (embedded part beyond the west portal) in
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order to restore the migratory routes and to obtain protection of the population from the noise, dust and emissions during the
tunnel building, as soon as possible. This corridor will serve the traffic during the tunnel building and will not burden public
access roads to the community and in the Marianka community itself. We require keeping the time for completion of this
section to the minimal extent and at maximum of 1 year.
10. Construction of the highway will be done with respect to the close proximity to the built up areas and maximum protection of
the population from the adverse impacts of the construction.
What section, from which side will be done first, will result from the construction organization plan (further referred as „POV“)
of the whole construction. Construction time (required max 1 year) will depend on the terrain complexity, construction
technology and other factors affecting the construction length.
11. We do not agree with postponing of our comments incorporation to the following stages of documentation. We require
incorporating all comments at this stage of EIA revision, not in the subsequent documentation stages, such a s planning
permission, building permission.
11. Comments raised at public discussions are of technical nature and due to project preparation it is possible to verify and
incorporate them in documentation for planning permit. It is not possible for the environmental experts – EIA Report elaborated,
to begin the highway projecting. It should be designed by technicians that have the required education and professional ability.
NDS has never, without any reason, postponed comments incorporation to „some” later stages of project documentation, but the
process for the motorways preparation, and not only for motorways is according to the current legislation ALWAYS the same.
To incorporate comments in the EIA process is unjustified requirement.
Conclusion: We require EIA redrafting according to above mentioned comments
Conclusion:
Rewriting or completion of the EIA Report, required by MŽP SR, that can do so within the statutory period, pursuant to § 31 sec.
3 of the Act. No. 24/2006 Coll. Of Laws on the assessment of the environmental impact (not later than 7 days) since receiving of
the Report by MŽP SR. The Report was received by MŽP SR on 9.3.2011. MŽP SR did not do so. MŽP SR circulated the Report
for statements, comments, as basis for public discussion with concerned state authorities and local governments and the public.
It is not possible to rewrite the EIA Report according to the above mentioned comments that are of technical nature. Technical
solutions would have to be designed by the EIA Report authors, who are not project designers, but knowledgeable
environmentalists.
The further stage of technical documentation is preparation of documentation for planning permission. In this documentation,
justified requirements and comments noted in the EIA process, can be considered, which will be stated in the concluding
statement.
OZ Malé Karpaty statement in the letter conclusion is unprofessional, incompetent and unrealistic.
Ing. Victoria Chomová – Investment Director, Member of the Board of Directors.
OZ Morava River in danger (letter dated 17.5.2011)
Let me respond in the reaction to subject matter about assessment, that our civic association does not agree with this report and
submits these comments:
Assessment report in number of points does not fulfil the scope of assessment under no. 7155/08 – 3.4/ml as
of 18. 7. 2008 and evaluation of the expected impacts is according to § 3 NR SR law Act. No. 24/2006 Coll.
of Laws, not complete and comprehensive. For example geological and hydrogeological surveys are
missing, required in point 19. In point 20, it was required to state the results of the hydrogeological
analysis of underground water flow changes.
According to § 6 of the Act No. 24/2006 Coll. Of Laws, if several proposed activities in the operational or
spatial context, their common assessment is possible. D4 highway from Jarovce section to Devínska Nová
Ves section was divided into four separate sections that were separately taken out of the context, assessed
already since 2011. Not all concerned communities were involved in assessment of the neighboring
sections that affected the route conduction and caused unfulfillment of citizen requirements for healthy
environment in their residential area. The right for healthy environment is included in the Constitution of
the Slovak Republic. Route conduction in Stupava South intersection above the I/2 road, affected route
conduction also for conjoining section in the cadastral area of Marianka Community that was assessed
independently and where citizens required route conduction in the kerf. Un-involvement of concerned
communities in the assessment of all sections is contrary to the Act. No. 24/2006 Coll. Of Laws.
First section of D4 highway to be assessed was section of D4 highway intersection DNV II/505-intresection
Stupava South, which subsequently predetermined route conducting to the west as well as east, without
directly addressing of the concerned communities in these conjoining sections.
In the evaluation report the purpose of the construction is defined unclearly and contradictorily. The
purpose of the construction in chapter A / ll / 2 the relief of Bratislava from freight transport is mentioned.
In defining the criteria for the selection of options in chapter C / V. it is stated and emphasized in
particular the impossibility of further urbanization of the area. We consider this fact as extremely
important that not only calls into question the very purpose of the construction, but also the option choice,
as there are no clear criteria according to which the construction is planned. Currently the regional
transport generel of the Bratislava Self-Governing Region is being acquired, which is to comprehensively
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evaluate the traffic in region territory. We believe that the EIA process for transport constructions should
follow after processing of the generel and analysing of transport needs and priorities of the region, it
highlights the non-conceptual NDS, a.s. approach
Transit traffic on the Lafranconi Bridge according to the elaborated’s data 69,631 car. / 24 hrs. 12.3% of
freight (2008). On page 22 Traffic-engineering documents it is stated in 2020 after building construction
64,589 vehicles / 24 hr., of which 16.26% for other vehicles, which also includes trucks. In the transport
survey statement of overload of Lafranconi Bridge already in 2015 without investment building. However
even if it is build, according to the available data, the overload will appear in about seven years since its
completion. Delay through city caused by passenger transport will therefore continue after the completion
of the D4 highway and lead to collapse on the Lafranconi Bridge also caused by the freight!!! Other
sections in the northwestern part of Bratislava appear to be similar.
It is necessary to solve transportation within Bratislava environmentally - support railways, public
transport (further referred to as “MHD”) and integrated public transport (further referred to as “IMHD”)
and other transport measures such as construction of inner city roads (inner city semicircle Lamač -
Galvani extension). We disagree with the building of the D4 highway without further measures, without
which in the northwestern part of Bratislava increase in transport (bringing traffic also from Austria) will
appear without systemic solutions. We require to take these binding measures and to declare together with
the provision of financial resources before building the D4 highway.
Circling of the traffic on the D4 highway and argument about sections interdependence has no traffic-
engineering justification. The semi-circle conducted in the capital city Bratislava territorial plan, with an
outlet in Lamač and on the other side, in the wider city centre solves serving of city with wider city centre
areas more effectively for passenger transport, while D4 address mainly freight transport and its diversion
out of town as indicated the purpose of the construction. As indicated above not even diversion of freight
transport is not efficient enough, and after launching the investment it will not relieve northwest from
freight.
Not all ÚSES elements are graphically represented. The regional bio-corridor led through Šursky kanál is
missing.
Mgr. Róbert Bardač – Executive Director
Basic organization SZZ 6-62 Stupava-Zlatá Hora (letter dated 19.5.2011)
We found out with regret that when assessing the impact of the D4 highway bypass on the environment we have not
been addressed. Our garden settlements are located in the cadaster Stupava-Mást in direct contact with the highway
bypass (which is situated east of the garden settlement).
Our principal requirements:
1 / We require the maximum possible embedding of the highway under the surface to minimize noise directly to our
garden settlements.
2 / We require unconditionally to ensure access to our garden settlement from Marianka community side (we
assume tunnelling solution - one tube).
3 / We require safe access to our garden settlements during the construction time and after the construction is
finished to restore quality road connectivity of the garden settlement from the Marianka community side (turning of
the Karpatska street at the bus stop in direction to Stupava).
Mgr. Nicholas Mojzeš – Chairman of the Basic organization
NDS, a.s. statement to the above mentioned requirements ZO SZZ 6-62 Stupava-Zlatá Hora
(letter dated 30.5.2011) To your letter dated 19. 05. 2011, by which you notified us that you were not addressed when assessing D4 highway, Ivanka
North-Záhorská Bystrica we announce:
When organizing public discussion, according to the Act No. 24/2006 Coll. of Laws on the environmental impact assessment we
have addressed all the affected communities. As you write, your gardening settlement is located in the cadastral territory Stupava
– Mást and Municipal Authority in Stupava knew that the public discussion of the Report on the assessment of the suburban
highway on the environment will be held in Lozorno for the Marianka,Stupava and Lozorno communities. All civil or local
authorities should communicate this fact to all concerned subjects in its cadaster.
To your principal requirements:
1. The highway was partially embedded below the terrain to protect residents from noise. On the basis of the same requirements
of Marianka citizens, in the next stage of the project documentation – in documentation for territorial decision the possibility of
conducting the highway in such a way so that traffic noise will bother the population in its vicinity in the least possible way, will
be studied.
2. By law all access roads that are interrupted by construction of the highway must be enabled in such way as they were before
the construction of the highway. If you have an access road to a garden settlement from the Marianka community, you will also
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have the access after the highway construction.
3. During the construction the access to the garden settlement will be granted.
We have sent copy of your letter to the MŽP SR, where it was necessary to send your comments and requests, and we also sent it
to the to Stupava civil authority.
Finally, we would like to remind you that the upcoming D4 highway is conducted in the corridor of the former Bratislava zero
circuit, which is in the Bratislava territorial plan as well as territorial plans of communities known to be affected for at least 25
years. Also all of you who established the garden settlement in Stupava cadaster - Mást surely knew that in this location there
would eventually be built higher category road. Prime circuit should have been high-speed communications, today it is a
highway.
Ing. Victoria Chomová - Investment Director, Member of the Board of Directors
Dušan Statelov, Bratislava (letter dated 05.20.2011)
Statement is identical with the statement of OZ Malé Karpaty dated 20.5.2011.
Dušan Statelov, Bratislava, e-mail (letter dated 08.21.2011).
Re-application for sending of audio recordings of public discussion and providing of Study of effectiveness and feasibility.
Mgr. Milan Hudeček, PhD., Marianka (letter dated 05.12.2011)
In particular, we appreciate that based on the assessment recommendation of option with extended tunnel and conduction
through the kerf and not on the mound, is recommended. However we solidly support the Senec - Pezinok – Lozorno option, or
other option solutions. Options 2a and 7a (with the highway conducted on the mound) are absolutely unacceptable for us and we
demand their exclusion from further consideration. We have no objections to 7c option in that we consider the sound insulation
as insufficient and there is no protection against emissions. Therefore we require finalization of option with overlay and
coverage with soil to the Záhorská Bystrica intersection.
At the same time we express our most definitive protest against formulation of chapter Brief description of impacts, according to
which "... ... variant 7c... its impact on the population directly affected is acceptable." Allow me little analysis of this situation
and of this statement. In the overwhelming majority here (in the area mostly affected by the highway) live people who put all
their means to the housing and will pay their mortgages for a long time to come. We moved here from Bratislava noise because
of quiet and healthy environment. When you build motorways under our windows that will roar at "only" 45 dB we are finding
ourselves in the environment from which we fled here. Even less savvy person will realize that our properties will become
unmarketable (anyone is lacking any motive to move here), or it will only be possible to sell, well below the price. Net result -
highway will deprive them directly of their money, quiet and environment, because of which they have invested their life savings
or it will deprive them of their money in selling their real estate below the price. If this is "acceptable impact on the population
directly affected", then it will certainly also be acceptable to pay us acceptable compensation. And I assure you that in that case
we will definitely seek compensation through the courts.
Mgr. Katarína Tupá, Bratislava (letter dated 10.5.2011)
I submit this statement to the MŽP SR as one of the many citizens who while realizing of their lifetime investment
and ensuring better quality housing and living conditions, not only for the present time, but especially for the future,
chose the Marianka community.
Not only for this group of citizens the implementation of the above mentioned project represents, as I was
acquainted with it recently, a huge impact to their rights and to peaceful enjoyment of their property while their
health is being threatened as well, in particular the underlying deterioration of the environment (already during the
construction ) and property (in particular any possible land shocks and landslides), in the manner and to the extent
that this project did not take into account at all, or did not consider in sufficient extent, same as it did not, or only
inadequately sorted out with the justification and assessment of the recommended option.
In this regard I dispute the following facts:
The submitted report about assessment is insufficient in terms of the content; the quality does not match the extent
of the expected investment and does not include a thorough assessment of the project's impact on the environment.
I consider the evaluation of the effects of the selected option on the environment, which is evaluated as "slightly
positive" to "strongly negative" for the prime option, which has no impact on the environment, as unjustified and
purposeful.
It seems to me that at given EIA stage specific evaluation is necessary for individual impacts on the environment
and specific population groups. The assessment report does not include such an evaluation at all.
I am pointing out that the assessment report lacks some surveys clearly defined in the scope of the assessment. It
does not contain specific compensatory measures with an assessment of their actual effects on the improvement of
the situation. These mandatory parts are compensated in the assessment report by statements that it "can be solved",
which is at this stage of the assessment inadmissible and, in my view, also contrary to the law.
The fundamental problem of the submitted assessment report is insufficient description of the purpose of the
construction and the absence of a thorough transport justification.
Despite the declared fact that the tunnel is to address the transit traffic (even provides transport to the Czech
Republic and Hungary), one of the most important arguments of the project is to address the traffic situation in
Bratislava, which lacks an objective analysis.
Required southerly option with the portal in Lamač, which the MŽP SR without giving a good reason did not
include in the scope of assessment in materials is missing despite the fact that after the analysis it could be
demonstrated that with this option, impacts on the environment are the lower, traffic usage is the highest and
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financial costs are lowest (this is clearly the shortest route).
Without any justification, at the western mouth of the highway, the desired subgrade variant is missing - none of the
options qualifies as under level conduction in the longest technically possible section to the intersection in front of
Stupava.
I consider that the failure to present the material of such radical nature, that this cannot be the subject of a proper
and objective assessment and evaluation, and also it is not in accordance with the law.
I propose to remove the above prime shortcomings to enable to detect from the submitted materials all the impacts
of the project on the environment and to allow these to be objectively assessed and evaluated.
Ing. Rastislav Galát, Bratislava (letter dated 10.5.2011)
Statement is identical with statement of Mgr. Tupá
(purposely ignored?) is in the light of these facts reasonable and truly address the transit traffic. Indeed, only when
connecting these three new intersections it will overload D1 just before Bratislava. SPL option would divert the
traffic in D2 direction, and in this section it would unload the traffic. These are the real reasons for the transport
review of "D4 Ivanka north - Záhorská Bystrica" routing. It should be noted that it is a big investment and therefore
public money should be used to really solve the traffic and not to satisfy the interest of investment groups.
It would be sufficient if the competent authorities acted correctly, based on objective professional transport analysis
– transport generel, based on their own investment planning based on real needs of citizens and the affected area.
Zita Búšová, Bratislava (letter dated 10.5.2011)
I protests against the construction of the D4, as its construction is determined along Šúrsky kanál near Moravod.
This option destroys the entire ecosystem in this area.
Why do we have environmental experts, when their recommendations are not respected? Who it actually is, what
department, which goes against logical thinking, it going to build 8-lanes D4? For what, when it will only be for
transit. Or does someone think that so many cars - trucks passes D4 daily? I think it's because of CEPIT.
And again I ask why is the more expensive option chosen, something similar has already been condemned under the
former government, do we have a surplus of money? I protest!
You, who approve destruction of nature, decide on D4 without considering how it will help citizens of Bratislava.
Wake up because when you create something like this mindlessly, it will not be possible to demolish.
Think of the citizens of Bratislava, we urgently need to tackle traffic in the city and not transit! It seems that you
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think more about CEPIT! But the territory is ours, belonging to Vajnory, our vineyards, our Šurský kanál, our pond!
How one does even dares against the expert assessment to build according to their wishes in spite of all the buildings
that we do not need and do not address the real problems of citizens Bratislava.
I protest, my mother, daughter and neighbours. Please, whoever can, stop them!!!
Mgr. Ing. Ivana Číková, Bratislava (letter of 16.5.2011) After getting familiar with the given material, I came to the following opinion:
1. The given material comprises some sections on negative impacts of the highway D4, that are incorrect or
intentionally altered in favour of the construction of the highway D4, or some negative impacts of the highway D4
specified in the given material are underestimated and some negative impacts of the highway D4 were not assessed
at all.
The noise study, being the text annex 2 to the given material comprises the incorrect application of the legal
regulation, namely the application that can be considered to be intentional in favour of the construction of the
highway D4.
The given material does not comprise the assessment of the impacts of the highway D4 on fauna present on the
NATURA 2000 territory of SKUEV 0279 Šúr, despite that there are the species protected for example by the
Council Directive 79/409/EEC of 2 April 1979 on the conservation of wild birds /the Birds Directive/ on the
territory. The Birds Directive is one of the directives regulating the subject of protection of the territories included to
NATURA 2000 system.
The given material does not comprise the assessment of the impacts of the highway D4 on the fauna species for
which the NATURA 2000 territory of SKUEV 0279 Šúr was declared for the purpose of their protection.
It comes to the dismembering of the intention of the highway D4 Ivanka North - Záhorská Bystrica and thereby also
to the dismembering of the assessment of the negative impacts of the highway on environment and the protected
natural territories included to the NATURA 2000 system especially.. Such dismembering does not allow the
complex assessment of the impacts of construction and the operation of the given highway. The given material deals
with the highway D4 to the extent of 4 lanes, ET they suppose the construction of the highway to the extent of 6
lanes right now. The proposed category of the highway D4 - D33.5/120 - see p. 10 of the given material
The fact the highway D4 is planned to the extent of 6 lanes is confirmed also by the information from the material
called Assessment Report - the Complementation of Highway D4 Jarovce - Ivanka North. In the material - the
Complementation of D4 Jarovce - Ivanka North, they state on p. 10 and 12 something like that - the other sections
outside the tunnel are designed in the category D 33.5/120. The 33.5 category with 4-lane width arrangement of
roadway, i.e. with wider separating belt so that its problem-free broadening to 6-lane towards the highway axis
would be possible in future.
-The given material does not comprise the assessment of negative impacts on aquatic animals that shall be
negatively affected for example by draining the highway while moving water to Šúr kanál, the Strúha brook, the
Lysý pond or infiltration area, whereby the contamination from D4 shall get also to the ground water in the
concerned territory.
I remind the water courses and a pond, to which they plan to lead water from the highway D4, are the aquatic
habitats of animals and they also serve as the source of drinking water for animals.
The given material does not comprise the cumulative assessment of negative impacts of the planned construction
and operation of the highway D4 on the concerned territory and especially on the protected natural territories. The
given material analyses individually, for example, some substances polluting air, but it does not deal with their
cumulative assessment and in addition also the quantities of these individual pollutants are under-assessed and the
similar non-cumulative approach is applied in the given material also for other negative impacts. Pollutants
/emissions/ noise, light smog, air overheating /change in micro-climate/, soil and water pollution would act in the
case of the construction of the highway D4 individually, but cumulatively, they would act concurrently and for a
long time or permanently and this represent substantially higher load for fauna and flora and for the entire concerned
territory than it is stated in the given material.
Not all the points of the Assessment Scope No. 7155/08-3.4/ml of 18.7.2008 /hereinafter referred to as the AS/ were
met.
The given material does not comprise the complex finding, description and assessment of the supposed negative
impacts of the proposed activity on environment.
It is given in details below.
2. The Noise Study /NS/, attached to the given material /text Annex 2/, on the basis of which some parts of the
given material are elaborated, was drawn up on the basis of the under-assessed intensity of transport on the planned
highway D4 - see Table 3 of the NS
-The prospective distribution of traffic - vehicles/24 hours - variant 2a,2ab,7a,7b,7c year 2040
D4 Ivanka West - Ivanka North in total 47,709 cars
Collectors 8,158 cars
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D4 Ivanka North - Čierna voda 36,526 cars
Collectors 27,250 cars
D4 Čierna voda - Rača 30,820 cars
Collectors unidirectionally 2,373 cars
It is apparent that in the case they would really expect such traffic intensities on the highway D4 as are stated in the
given material, they would not consider the construction of highway D4 as 6-lane road. And they consider the
construction of 6-lane road.
Even nowadays for example the section of the expressway Trnava - Sereď has an annual average daily intensity of
43,316 cars, the sections of the highway Dl Senec -Trnava 50,432 cars, Piešťany - Nové Mesto n. V. 31,026 cars
and the new section of Bytča 23,674 cars. It is clear that on the highway D4, with regards to its planned location in
Bratislava and the intended connection of the other intentions to the highway D4, we must take into account even
greater traffic intensity than that one being base for the given noise study. The highway D4 is planned as the
connection line of the highways of D1 and D2. Nowadays, the annual average daily intensity expressed as the count
of cars on the highway D1, the section of Senec-Bratislava ranges from ca 70,000 to ca 100,000 cars and on the
section of Prístavný Bridge in Bratislava it equals to ca 100,000 cars. Noise produced by just a single passenger car
during the drive is around 73 dB/A/. In addition, they planned also the connection of automotive transport to the
highway D4 e.g..:
- From Chorvátsky Grob, where they planned the residential development for ca 40,000 people
- From the former airport in the municipal part of Bratislava - Vajnory, where they planned the residential
development for ca 22,000 people
- From CEPIT in the municipal part of Vajnory, where they plan warehouse areas and the residential construction
for ca 20-30 thousand people,
- They plan the connection of automotive transit almost from the entire Slovakia to the highway D4 in the direction
to the Czech Republic, Austria and Hungary,
- According to the published information, they plan the connection of the European transit of automotive transport to
the highway D4, the bilateral interconnection of the North and the South of Europe /in the direction from
Scandinavia to the Black sea/.
With regards to the contemporary traffic on the highway D1 and the planned intention that should be connected to
the highway D4, I consider the traffic intensity on the planned highway D4; they came from in the given material, to
be undervalued. With regards to the above stated, I consider the noise load from the planned highway D4 stated in
the given material to be undervalued.
The noise study comprises the incorrect application of the legal regulation. This regards the application of clause
1.6. of the Annex to the Regulation No. 549/2007.
I can note this clause 1.6. does not relate to the noise from the planned road communication, but it relates to the
existing noise. That means the clause 1.6 is pointless from the point of view of the planned road communication and
it may not be applied due to the noise from the planned highway D4.
3. The Dissipation Study /DS/, attached to the given material /text Annex 2/, on the basis of which some parts of the
given material are elaborated, was drawn up on the basis of the under-assessed intensity of transport on the planned
highway D4. According to Table 2 of the DS - The traffic prognosis for the situation with the construction of the
highway D4 in variant 2a,2b,7a,7b,7c year 2030
- D4 Ivanka West - Ivanka North section totally 41,437 cars
- D4 Ivanka North - Čierna voda totally 31,498 cars
- D4 Čierna voda-Rača totally 26,578 cars
- D4 Rača-Záhorská Bystrica totally 25,244 cars.
The calculation of the imissions from traffic is based on the traffic intensity and emission factors of motor vehicles -
see p. 2 of the DS.
As for the contemporary traffic intensity on the highway D1 and the expected traffic intensity on the highway D4,
similar shall apply for the DS as is stated above in clause 2 hereof. I further comment the DS on the immissions
from transport, that came from the undervalued traffic intensity projected for 2030 on the highway D4 and from the
alleged emission factors for 2030, they were compared with the contemporary limits, and in addition, the limits were
contemporary short-term limits despite that the effect of immission load from the planned highway D4 would be
long-term or permanent. From this point of view, we can consider also the annual limit to be short-term. The
planned commencement of the traffic on the highway D4 is in 2015. For the objective assessment of the immission
lad from the planned highway D4, we cannot come from the alleged emission factors for 2030 that are substantially
lower than the contemporary emission factors and the alleged emission factors for 2030 are apparently lower than
the emission factors for 2015 and the nearest subsequent years. We may justifiably reckon that in the case they
would come from the emission factors for 2015 in the calculation of the immissions of pollutants from the highway
D4, the results would be substantially worse and their negative impacts on specially protected natural territories and
the health of people in the concerned territory would be substantially more serious than it is stated in the given
material based on the undervalued input data - i.e. from the undervalued traffic intensity and the undervalued
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emission factors. And substantially more serious negative impacts on environment than those ones specified in the
DS and the given material may be justifiably expected in the concerned territory in the case of the construction of
the highway D4.
Since they came from the undervalued emission factors and the undervalued traffic intensity on the highway D4
when calculating imissions from the highway D4, it came to the undervaluation of the emissions from operation and
thus also to the undervaluation of immission load from the planned highway D4. Similar statement applies also to
the calculation of immissions from the highway D1 with regards to the used emission factors. And this implies also
the existing immission load from the highway D1 was undervalued. The cumulative effect of the existing highway
D1 and the planned highway D4 was undervalued in the given material as well.
Should they came from the objective and not undervalued input data in the calculations, when assessing the impacts
of the highway D4 it would be revealed that the construction and operation of the highway would have a serious
negative impact on human health and the specially protected natural territories located in its concerned territory. The
procedure applied in the DS and in the given material is considered by me to be the intentional modification of the
assessment of the impacts of the highway D4 on environment in favour of the construction of the highway.
The negative influence of emissions from automotive transport on environment and human health is stated in details
in the standpoint of 11 June 2008 to the material named "The Intention of the Highway D4 Bratislava, the
intersection of Ivanka North - Stupava, that was delivered to the Ministry of Environment of the Slovak Republic on
16 June 2008.
4. The given material does not comprise the assessment of the impact of carbon dioxide /C02/. By burning one litre
of fuel, approximately 2.5 kg of C02 is produced. C02 is heavier than air and at the concentration of around 3% it is
harmful for organisms.
The given material does not comprise the assessment of the impact of ozone. The negative influence of ozone on
fauna and flora in the concerned territory is stated in details in the standpoint of 11 June 2008 to the material named
"The Intention of the Highway D4 Bratislava, the intersection of Ivanka North - Stupava that was delivered to the
Ministry of Environment of the Slovak Republic on 16 June 2008.
The given material does not comprise the cumulative assessment of the negative impacts of air pollutants from the
traffic on the highway D4 in the considered territory. Air pollutants would not act individually in the case of the
construction of the highway D4, but they would act concurrently, together and for a long time.
The given material does not comprise the assessment of the impact of vibrations during the construction and
operation of the highway D4 for example on the stability of the dams on Šúr kanál, which is in disaccord with the
Clause 23 of the AS.
The given material does not comprise noise and dissipation study for the period during the construction of the
highway D4 and this is in disaccord with the Clause 18 of the AS
The highway D4 - variants 2a,2b,7a,7b,7c are planned almost at the boundary of the protected zone of the National
Natural Reserve /NPR/ Šúr, considered for the purposes of the assessment of the impacts to be the protected
territory pursuant to Article 103 Para 5 of the Act No. 543/2002 Coll. Pursuant to Article 103 Para 5 of the Act No.
543/2002 Coll. on the protection of nature and landscape for the purposes of the assessment of impacts on
environment, the protected zone of the protected territory is considered to be the protected territory pursuant to the special regulation. The given material does not comprise the assessment of the impacts as it is stipulated by Article 103 Para 5 of the
Act No. 543/2002 Coll.
The highway D4 is planned almost at the boundary of the NPR Šúr, alongside the entire Western boundary of the
reservation at the lengt of ca 4.5 km. The highway D4 is distant just ca 50 m from the territory of the NPR Šúr in a
certain spot.
There is not information in the given material the NPR Šúr, including this protected zone, is the Ramsar location, i.e.
the wetland of the international importance protected by the Agreement on wetlands having the international
importance, in particular as the habitats of aquatic birds /the Ramsar Agreement/. In addition, there are the species
protected:
- By the Convention on the Conservation of Migratory Species of Wild Animals /the Bonn Convention/,
- By the Convention on the Conservation of Bats in Europe,
- By the convention on the Conservation of Afro-Asian Species of Aquatic Migratory Birds, - By the Convention on
the Conservation of European of European Wildlife and Natural Habitats / the Bern Convention/
-By the Council Directive No. 79/409/EEC of 2 April 1979 on the conservation of wild birds /the Birds Directive/
on the territory of the reserve the NPR Šúr is the territory that is unique within Central Europe. The NPR Šúr is the
last territory of the type in Central Europe. It is the last specimen of how the region would have looked like 10,000
years ago.
There is NATURA 2000 territory of SKUEV 0279 Šúr in the NPR Šúr, with the presence of priority habitats and
priority species.
This is the natural heritage of the European Union and the Slovak Republic. The following is stated on p. 84 of the
given material - I quote: " The significant eco-stabilisation element with large or even extraordinary large
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importance in the assessed territory is the wetland region of the National Natural Reserve Šúr spreading out on the
area of 370 ha that contributes to the overall stability of the territory and improves the resistance of the landscape
towards changes in the proximity of the location. This notable eco-stabilisation area is followed by an artificial
drainage Šúr kanál that is gradually changing to semi-natural, nature-close element with medium importance for
ecological stability of the territory"... The end of the quote. It is stated on p. 164 that it would not come to more
significant negative impact on the protected territory and its protected zone. I consider this statement of p. 164 of the
given material to be false.
In fact, the construction and operation of the highway D4 would have a serious negative impact on the Ramsar
location of the NPR Šúr and the territory of SKUEV 0279 Šúr In the case of the construction of the highway D4, it
would come to:
- The isolation of the NPR Šúr, its segregation from the surrounding territory, alongside the entire Western part of
the NPR Šúr at the length of ca 4.5 km.
The negative impacts of the highway D4 would cumulate on the territory of the reservation, namely:
- Noise,
- Air pollution,
- Water and soil pollution,
- Ozone,
- Light smog,
- The change in climatic conditions /territory overheating/,
- The fragmentation of the habitats of animals living on the territory of the reserve, including the species protected
by international agreements binding the Slovak Republic. Some species from the specially protected natural
territories would be separated by a permanent line obstruction from their feeding habitats, - The introduction of
invasive species to the specially protected natural territories, - The killing of animals from specially protected
natural territories, including the specially protected species on the highway D4.
- The reduction of biodiversity, the reduction of the number of species and abundance of species,
-Anti-noise shields and fencing alongside the highway would act as an animal trap, e.g. for ornithofauna and also for
the other species. And also for example at the exit fro the tunnels, they act as barriers and traps for animals.
- The disturbance of animals,
- The stressing of animals,
- A permanent line obstruction would be created preventing the migration of animals, in particular ornithofauna,
including the specially protected species.
The above stated negative impacts deteriorate the quality of habitats. Black Stork occur in the NPR Šúr and it was
observed also on the territory in the proximity of Šúr kanál. I state to this the following from the given material:
Some pollutants and their quantities getting to water and soil from the highway are given in the Table on p. 64 of
text Annex 4 to the given material. This is for example lead, cadmium, nickel, mercury, chromium, copper, zinc,
chlorine, carbon 10-40, polyaromatic carbohydrates /PAC/. While it is stated on p. 64 next to the given Table the
results stated in the Table come from the measures on the highways and expressways that are more frequently used
than the SPL variant of D4, the assessment of which used the above mentioned Table of p. 64. I note to this that the
traffic intensities they came from in the given material are undervalued. Details on traffic intensity are given above.
The given water course affected by the SPL variant probably serves as the food base for nesting Black Storks - see
p. 63 of the text Annex 4 to the given material.
I quote the comments t the above Table on p. 64 from the given material: ..."With regards to low aquosity of the
recipient, the given concentrations shall be diluted only to a limited extent and thus we may suppose the quantity
and quality of aquatic zoocoenoses might be reduced, and it may come to the cumulation of selected elements and
compounds in them. With regards to the fact the Stork may be considered to be the peak predator in the concerned
section of the CHVÚ in this connection, accumulation may be demonstrated in more significant way in it. This may
then have the negative impact for example on reproduction ability or mortality of young animals". The end of a
quote.
I note that the given material impresses me as being compiled with the aim to induce a deprecatory attitude of the
reader of the material to the variant labelled as SPL on one hand and the given material plays down or undervalue
the negative impacts of the variants of the highway D4 planned almost at the Western boundary of the NPR Šúr on
the other hand.
The impact of the planned highway D4 on the quality of ground water was not assessed. "The quality of ground
water is significantly affected by rock environment and also the quality of surface water greatly contributing to the
replenishment of ground water supplies. The source of water pollution is also transport, since it comes to the
washing out of contaminated water from the communications to surface waters or infiltration to ground waters.." ..."
Last but not least, the source of water pollution is also the polluted rain water." The end of quotes from p. 118 of the
given material. All forms of water pollution mentioned in the above quotes would take place in the concerned
territory in a direct causal relation to the construction and operation of the highway D4. The contamination of
ground water could take place due to the accident when digging out Vajnory tunnel, when establishing the bridge
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pillars and in particular due to the use of chemicals and injection when digging out the tunnel.
The given material does not comprise the results of hydrological analyses of the changes in flow of ground water
due to the implementation of the proposed activity, which regards the NPR Šúr. It is stated on p. 164 of the given
material that the influence of aquatic regime in the location of the NPR Šúr was not supposed. I do not consider such
affirmation to be the result of hydrological analyses. Pursuant to the clause 20 of the AS, the Assessment Report
should include the results of hydrological analyses of the changes in flow of ground water due to the implementation
of the proposed activity.
It is stated on p. 66 of the given material that ground water in the municipal part of Vajnory lows from the Lesser
Carpathians towards the SE, in parallel with Šúr kanál. I quote from p. 43 of the given material: ..." The alternative
of the construction of the highway D4 in the section with Vajnory tunnel / the section of Western edges of fluvial
complexes between Ivanka North intersection - Rača intersection/ shall have a significant impact on ground water,
since the natural level in fluvial sediments has a significant seasonal fluctuation, with a short-term period up to the
terrain level." The end of the quote. It is stated on p. 10 of the given material something in the sense that the variants
of the highway D4 not considering the construction of Vajnory tunnel thus exclude the construction of sealing tank
under the level of ground water, during the construction of which it would be necessary to use more demanding
construction technologies and to impair the regime and quality of ground water during the construction. ..." When
constructing the dug out tunnel named Vajnory, the construction works and the object of the dug out tunnel shall be
significantly affected by the collector of ground waters - gravel and sand sediments." -The quote from p. 133 of the
given material.
I note that with regards to the fact the given material deals with the highway D4 within the range of 4 lanes, but the
highway is planned in the range of 6 lanes, we may consider also the quantities of rain water running from the
surface of the planned highway D4 /for example the Table on p- 34 of the given material/ and the resulting negative
impacts in the given materials to be undervalued.
I note that they assessed the variant of Bernolákovo - Svätý Jur - Lozorno in the given material. Such variant is not
mentioned in the AS. The variant of Bernolákovo - Svätý Jur - Lozorno is incorrectly designated as variant of Senec
- Pezinok - Lozorno in the given material.
The impacts of possible fires in the tunnels, e.g. in Karpaty tunnel and Vajnory tunnel, planned in the proximity of
the residential zone, and their effects on the close specially protected natural territories and residential zone are not
assessed in the given material . The planned Vajnory tunnel was not assessed as the stationary source of air
pollution during the operation of the highway D4.
The given material does not comprise the assessment of noise load from the planned highway D4 on the NATURA
2000 territory of SKUEV 0279 Šúr.
I quote from p. 118 of the given material: ..." From the point of view of the noise load, the assessed territory belongs
to the most loaded ones in Slovakia. The source of noise is mainly automotive transport, air transport and railway
transport. The sources of noise from road transport in the assessed territory is in particular the corridor of the
highway D1, road II/502, I/2 and the network of road communications of lower categories.
The source of noise from air transport is the airport of M.R. Štefánik. The noise from airport operation affect the
most the municipal parts of Vajnory and Rača.
The source of excessive noise from railway transport in the assessed territory is the busy railway routes No. 120
Bratislava - Žilina and No. 130 Štúrovo - Bratislava" The end of the quote.
With regards to the clause 1. of the AS I note that the planned highway D4 is in disaccord with sustainable
development and its construction would mean the unbearable load on the concerned territory. According to the
relevant regulations, the territory may not be loaded by a human activity above the level of the tolerable load.
It is stated in details in the standpoint of 11 June 2008 to the material named "The Intention of Highway D4 Ivanka
North - Stupava intersection that was delivered to the Ministry of Environment of the Slovak Republic by me on 16
June 2008. I quote from p. 120 of the given material: ..."According to the environmental regionalisation of Slovakia
from 2008, the greater portion of the assessed territory is classified as heavily impaired, the smaller North part of the
assessed territory is classified as the impaired environment. Bratislava is earmarked in the assessment as unhealthy
/endangered area together with the other 8 areas within the entire republic." ... "The South part of the assessed
territory regards the dense construction in the municipal parts of the capital city of Bratislava, the density of
settlements as well as of inhabitants reduces towards the North" The end of the quotes. I quote from p. 136 of the
given material: "The impact of the highway D4 would be most sensitively perceived in radiant weather due to the
bad dissipation of air pollutants and the subsequent smell produced by traffic in the proximity of the structure body
itself. From this point of view, the most critical situation shall be at tunnel ducts, where the contaminated air from
the tunnel shall be concentrated. In advection /windy/ weather, the construction of the highway shall contribute to
the increased coarseness of the active surface, which shall mean the increase in the presence of viruses in the
ground layer of atmosphere and the transfer of air pollutants to the higher layers of atmosphere"..." They suppose
the impacts on the local climate and micro-climate in the proximity of newly constructed highway D4." The end of
the quotes. I can note down to this that "While 60-70% of the falling solar radiation is transformed to
evapotranspiration on the area with an abundant vegetation in a hot sunny day and just 5-10%shall be transformed to
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the perceived heat, it shall be vice versa on the drained area . Thermal energy produced this way on a hot summer
day in the central zone represents 4-5kWh per m2. This is the energy corresponding to the energy contents of 1 kg
of coal. The energy comparable with the energy released due to the perfect combustion of 750 - 1000 ton of coal
shall be released on the drained area of 100 ha within a single sunny day. - The quote from www.ludiaavoda.sk. I
can add to this that the further thermal energy is generated during the operation of the cars and it is also released to
the surrounding environment and the third factor is air polluted with emissions, that is overheated more than the air
polluted with emissions from automotive transport. Territory overheating damages also the habitats. Overheating is
harmful for almost all living organisms.
I state to this that according to the given material, they consider the land seizer of from ca 63 hectares t ca 92
hectares of land for the individual variants of the highway D4 planned alongside the Šúr kanál, while the seizures
probably do not count in the seizures for the construction of collectors.
I state to the point 2 of the DS that the traffic prognoses for the highway D4 were undervalued in the given material.
It is given in details above.
The purpose of the construction is in the given material inter alias justified by the planned implementation of
developers intentions in Vajnory - CEPIT and the construction on the former airport in Vajnory. These are the plans
focused on profit for the groups of people promoting the intentions. Both the intentions are unsuitable for Vajnory.
The development is just better sounding label for fiddling with real estates.
Another justification of the highway D4 stated in the given material is the diversion of transit transport leading from
Chorvátsky Grob through Vajnory. I note to this that it is possible to construct a branch to the existing highway D1
for Chorvátsky Grob and thus the transit would be diverted outside the local communications in Vajnory. The
highway D4 would have even more negative impact on Vajnory than the contemporary transit from Chorvátsky
Grob.
CEPIT, the planned construction works on the airport in Vajnory and the highway D4 are not the development.
Their impact on the concerned territory in the case of their implementation would be devastating and degrading. The
intentions are in a direct conflict with the definition of the territorial development pursuant to Article 139a Para 7 of
the Construction Act. Details on transport are given in the standpoint of 11 June 2008 I delivered to the Ministry of
Environment of the Slovak Republic on 16 June 2008.
The given material does not deal with the fact the highway D4 would cause the reduction in the value of real estates
intended for living and gardens near the houses in the concerned territory.
The negative impact of the highway D4 on the appearance of the concerned territory was undervalued in the given
material. I quote from p. 162 of the given material: ..."since the highway shall be shifted before Šúr kanál that forms
a visual barrier in the territory and the perception of a new element in the landscape would not be produced."
It is clear that on contrary to the body of the planned highway D4, the dam of Šúr kanál they do not affect the
appearance of the concerned territory in interfering way. The highway D4 would degrade the appearance of the
entire territory from the GSI Ivanka North as far as the entry to the Karpaty tunnel. This would regard the highway
body itself on several-meter filling with installed anti-noise screens having various heights. The concrete curbs with
the height of ca 1.2 m would be located at the circumference of the highway, the highway would be fenced, the
concerned territory would be segmented by several bridges and three grade separated intersections. The collectors at
the sides of the highway D4 should be added to this and someone dares to assess this highway from appearance
point of view as approximately equivalent with the look of Šúr kanál?
5. The given material inter alia provides the information on the approval of the route of the highway D4.
I note to this as follows:
The route of the highway D4 was approved by the government of the Slovak Republic within the strategic document
named "The Program of Preparation and Construction of Highways and Expressways for 2007 - 2010". They
adopted the Resolution of the Government of the Slovak Republic No. 1084/2007 in the matter of this strategic
document. The relevant legal regulations were breached in this approval process. The details on the breach are
below. The European Commission /EC/sent a call to the Slovak Republic regarding the Program of Preparation and
Construction of Highways and Expressways for 2007-2010 /hereinafter referred to as the PPVDRC/.
I quote to the question from the letter of the Ministry of Transport, Construction and Regional Development of the
Slovak Republic No. 07138/2011/OW-6 of 19 January 2011: ..."The EC in its call expressed the opinion that the
Slovak Republic did not applied the conditions resulting from the Articles 3-10 of the Directive No. 2001/42/EC /the
SEA Directive/ on the assessment of the effects of certain plans and programmes on the environment on the "
Program of Preparation and Construction of Highways and Expressways for 2007 - 2010" adopted by the Resolution
of the government of the Slovak Republic No. 1084/2007. The government of the Slovak Republic was called to
submit its comments to the EC within two months as of the date of the delivery of the letter, i.e. before 25 January
2011. On the basis of the formal notice of the EC, the standpoint of the Slovak Republic shall be elaborated and it
shall be submitted to the EC through the Ministry of Foreign Affairs of the Slovak Republic. The analysis of the
contents of the formal notice implied the sections stated in the Operation Program of Transport /the sections were
assessed pursuant to the SEA Directive in 2006-2007/ are identical with the sections stated in the document "The
Program of Preparation and Construction of Highways and Expressways for 2007 - 2010" save the section of the
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highway D4 the implementation of which was not considered in the given period.
However, this section is a subject to the SEA assessment, that is contemporary carried out for the planning scheme
of the region of Bratislava Self-government Region /ÚP VÚC Bratislava/. However, it shall be necessary to note
that despite that the SEA assessment for the highway D4 is just in progress, the individual sections of zero bypass of
p Bratislava, /the highway D4/ have EIA assessments that are more detailed than the SEA assessment of the impacts
on environment."... The end of the quote.
I comment on the quoted statement of the Ministry of Transport that the PPVDRC is a strategic document of a
national importance that may not be approved without the assessment of its impacts on environment. That means the
new definition of highways comprised in the clause 2.2.1 of the PPVDRC including the highway D4 may not be
approved without the assessment of impacts on environment. Such impact assessment did not take place. That
means the approval of the route of the highway D4 took place in disaccord with the relevant legal regulations. And
the breach on the legal regulations may not be remedied by assessing the D4 within the planning scheme of the
Upper-tier Territorial Unit. The powers of the Upper-tier Territorial Unit do not include the designation and
approval of highway routes. Just such highway route could be taken over to the planning scheme of the Upper-tier
Territorial Unit that was lawfully approved by the relevant authority and in accordance with the relevant legal
regulations. And this did not took place in the case of the highway D4 and this lawless condition would not be
changed even by the fact the EIA assessment of the individual sections of the highway D4 take place.
The resolution of the government of the Slovak Republic No. 1084/2007 was adopted in the matter of the strategic
document named "The Program of Preparation and Construction of Highways and Expressways for 2007-2010".
This is the material of the department of the Ministry of Transport, Posts and Telecommunications of the Slovak
Republic /the MDPT SR/, No. 1140/M-2007/ and the presenter is the Minister of Transport, Posts and
Telecommunications of the Slovak Republic. The material was presented to the session of the government of the
Slovak Republic No. 73/2007 on 19 December 2007, agenda point 7. I can say to the materials of the Resolution of
the government of the Slovak Republic N. 1084/2006 the following:
1. / It is incorrectly stated in the part of the material - the Assessment of the Consultation Proceeding within the
evaluation of the comment of the Ministry of Environment of the Slovak Republic /MŽP SR/ that, I quote: "The
Program absolutely takes over the Operation Program Transport for 2007-2013, for which they issued the standpoint
of the Ministry of Environment of the Slovak Republic No. MŽP SR č. 7721/2006 3.5. /ml pursuant to the Act No.
24/2006 Coll. of 28.2.2007."...
In fact, the highway D4 is included in the Operation programme Transport 2007-2013 with the length of 2 or 3 /say
two or three/ kilometres, while this is the route of the highway D4 from the state border of Austria/Slovakia as far as
the intersection of the highway D4 with the highway D2 in Jarovce and thus it is not true at all that the PPVDRC
shall not completely take over the Operation Program Transport for 2007-2013since the highway D4 is elongated
from the original length of 2 km to the length of 49 km in the PPVDRC.
I quote from the Operation Program of Transport 2007-2é13, p. 20, paragraph 3.3.2 - ..."The scope of the highway
network and the expressway network in the Slovak Republic is defined by the highway routes of D1, D2, D3 and D4
with the overall length of 659 km. The Table N. 14 on p. 21 of the OPT states the planned length of the highways in
kilometres - the highway D2 - 80 km, D1 - 517 km and D3 - 59 km. This means total 656 km plus 3 km- D4, thus
659 km in total.
In the PPVDRC, clause 2.2.1. The new definition of the highway network is stated - I quote: "The most significant
changes in the definition of the highway network are on the route of the highway D4, so called zero circuit of
Bratislava." "The proposal: to include in the highway D4 route the entire proposed so called zero circuit of
Bratislava /the intersection with D2 Jarovce - the intersection with D1 Ivanka pri Dunaji - the intersection with the
road II/502 - the intersection with the road I/2 - the intersection with D2 Stupava South - state border of the Slovak
Republic/Austria/ whereby the highway D4 shall be prolonged from the original length of 2 km to the length of 49
km with the supposition the circuit shall be dealt with using a double-tunnel and two portals /one behind Rača and
the other one behind Marianka/ under the Lesser Carpathians, without the external impact in natural and recreational
zone of Bratislava, the outskirts parts and surrounding villages /Svätý Jur, Borinka, Stupava/. The overall length of
the highway network versus the New Project of the Constriction of Highway and Expressways shall be amended
from 659 to 704 km. The difference in the overall length of the highway network versus the New Project of the
Construction of Highways and Expressways is implied by the clarification of the overall length of highways
pursuant to the project documentation and the individual structures and the elongation of the highway D4.".., The
end of the quote.
This implies the highway D4, the given section of the highway D4 included in the material named "The Program of
Preparation and Construction of Highways and Expressways for 2007-2010, to which they adopted the Resolution
of the government of the Slovak Republic No. 1084/2007 of 19.12.2007, is not included in the Operation Program
Transport 2007-2013, approved by the Resolution of the government of the Slovak Republic No. 1007 of 6.12.2006
and thus it is not true that the Program of Preparation and Construction of Highways and Expressways for 2007-
2010 shall be completely taken over by the Operation Program Transport 2007-2013.
The Program of Preparation and Construction of Highways and Expressways for 2007-2010 approved by the
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Resolution of the government of the Slovak Republic No. 1084/2007 on 19.12.2007 comprises the definition of the
highway network and the new definition of the expressway network. The highway D4 State border of Austria/the
Slovak Republic - Bratislava - the D2 Jarovce intersection - the Rovinka intersection - the intersection with D1
Ivanka pri Dunaji-North - the intersection with the road II/502 - the intersection with the road I/2 - the intersection
with D2 Stupava South - state border of the Slovak Republic/Austria is stated in Annex to the Act No. 669/2007
Coll. 2/ The Operation Program Transport 2007-2013- the version that was approved by the Resolution of the
government of the Slovak Republic No. 1007 of 6 December 2006, was the subject matter of the proceeding on the
assessment of impacts on environment regulated by the Act No. 24/2006 Coll. and the Ministry of Environment of
the Slovak Republic issued the standpoint to the impact assessment OPT No.. 7721/2006-3.5/ml o f 28.2.2007.
The Act No. 24/2006 Coll. on the assessment of impacts on environment and on the amendment and
supplementation of some acts entered into force on 1 February 2006.
The highway D4, the given section of the highway D4, stated in the PPVDRC, was not assessed pursuant to the Act
No. 24/2006 Coll. within the strategic document Operation Program Transport for 2007-2013.
And the Program of Preparation and Construction of Highways and Expressways for 2007-2010 was not the subject
of the assessment of impacts on environment pursuant to the Act No. 24/2006 Coll, despite that this is a strategic
document subject to the mandatory assessment of impacts on environment pursuant to the Act No. 24/2006 Coll.
The Program of Preparation and Construction of Highways and Expressways for 2007-2010 approved by the
Resolution of the government of the Slovak Republic No. 1084/2007 is, in particular with regards to the facts stated
in this letter, illegal, lawless. And in addition, also in the case of the Operation Program Transport 2007-2010, they
proceeded in illegal, lawless way, inter alia they proceeded on contrary to what is stipulated by the Act No. 24/2006
Coll. /e.g. Article 15 of the Act No. 24/2006 Coll./ Since the OPT was at first approved by the government of the
Slovak Republic on 6 December 2006 and only afterwards the standpoint of the Ministry of Environment of the
Slovak Republic No. 7721/2006-3.5/ml. of 28.2.2007 was issued. In addition, the strategic document Operation
Program Transport for 2007-2013 presented to the government of the Slovak Republic and approved by the
Resolution of the government of the Slovak Republic No. 1007/2006 probably did not passed the entire proceeding
of the assessment of impacts on environment, but it was just the subject of a part of proceeding - the assessment of
the impacts on environment regulated by the Act No. 24/2006 Coll. - the Operation Program Transport for 2007-
2é13 was elaborated at least in two versions. The versions differ from each other for example by some planned
sections of highways and expressways.
The assessment of impacts on environment was commenced probably with first version of the Operation Program
Transport 2007-2013 and it was probably completed with second version of the operation program, in disaccord
with the relevant legal regulations and in disaccord with the relevant legal regulations also since the assessment of
impacts was completed only after the approval of the OPT by the government of the Slovak Republic. Inter alia,
such a procedure is able to breach the rights of citizens and to prevent some villages, some subjects concerned for
example due to the amendment in the route of the prepared highways and expressways to participate in the
proceeding on the assessment of the impacts of the strategic document on environment, in particular by the fact they
became the concerned subjects only upon the amendment in the route r the amendment in the range of the route of
the prepared highways and expressways in later phase of the proceeding on the assessment of the impacts of the
strategic document on environment and therefore they were unable to submit their standpoints, comments, they were
unable to enforce their rights in full pursuant to the Act No. 24/2006 Coll.
It is also necessary to state that the Act No. 24/2006 Coll. regulating the proceeding on the assessment of the impact
of strategic documents on environment does not stipulate or regulate the possibility of the change of the strategic
document during the procedure on the assessment of the impacts of the strategic document on environment.
The Ministry of Transport, Posts and Telecommunications of the Slovak Republic, being the procurer of the OPT
submitted the strategic document, the Operation Program Transport for 2007-2013, to the Ministry of Environment
of the Slovak Republic for the procedure of the assessment of the impacts of the strategic document on environment,
is the central state administration body. Pursuant to Article 2 Para 2 of the Constitution of the Slovak Republic, the
state authorities may act only on the basis of the constitution, within its limits and to the extent and using the way
specified by the law. The Ministry of Transport, Posts and Telecommunications of the Slovak Republic went beyond
its powers determined by the law.
The Act No. 24/2006 Coll. obliges to have the strategic document subjected t the environment impact assessment at
first and only afterwards the strategic document may be approved and when approving it, they must consider the
existence and the contents of the final standpoint from the assessment of the strategic document. Such procedure is
warned also by the standpoint of the Ministry of Environment of the Slovak Republic stated in the Assessment of
the Comments to anther strategic document, the Program of Preparation and Construction of the Network of the
network of roads of class I for 20072010 /hereinafter referred to as the PPVSC/.
I read from the standpoint of the Ministry of Environment of the Slovak Republic to the PPVSC ... "The given
program is subject to the process of the environment impact assessment pursuant to the Act No. 24/2006 Coll. on
the assessment of the impacts on environment and on the amendment and supplementation of some acts /hereinafter
refereed to as the "Act" /, the process must be carried out before the approval of the given strategic document with
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the national reach. The results of the process of the assessment of impacts of the program on environment and the
consideration of the assessment of the presented standpoints together with their elaboration must be submitted by the
presenting party /the Ministry of Transport, Posts and Telecommunications of the Slovak Republic/ in the clause
on environmental impact.. The contents of the clause on environmental impact that should be the part of the material
presented for approval to the government of the SR is in Annex 2 to the Act.
"As long as this is the question of the reasonable assessment pursuant to Article 6 Para 3 of the Habitat Directive, it
is necessary to point out to the fact this stipulation does not define any particular method for the execution of such
assessment. Despite that, in accordance with the wording of this stipulation, the due assessment of the consequences
of the plan or project fr the relevant location must precede its approval and it must consider all the cumulative
effects resulting from the combination of the plan or project with the other plans or projects with regards to the
objectives of the location protection."... The quote from the precedence law of the European Court of Justice C-
127/02 - „Waddenvereniging a Vogelbeschermingsvereniging"
Pursuant to Article 15 Para 2 of the Act No. 24/2006 Coll. the approving body may not approve the strategic
document that is the subject of the assessment without the final stipulation from the assessment of the strategic
document or without the clause on the impact on environment. The Operation Program Transport for 2007-2013,
approved the Resolution of the government of the Slovak Republic No. 1007/ 2006 Coll. is lawless in particular
with regards to the above mentioned facts. The strategic document of the Operation Program Transport for 2007-
2013, i.e. the highways and expressways based on the OPT, or their parts, are not able to be transferred to the
legislative tests of the act drafts for the reason if its illegality, lawless character and thus the highways and
expressways or their parts based on the OPT may not be stated in the act draft and the Act amending the Act No.
669/2007 Coll. thus they may not be stated in the Act No. 669/2007 Coll. as amended either. Some of the highways
and expressways, or they parts, based on the OPT, are projected in the Act No. 669/2007 Coll. despite that the above
mentioned facts. 3/ The Program of Preparation and Construction of Highways and Expressways for 2007-2010, for
which they adopted the Resolution of the government of the Slovak Republic No. 1084/2007 of 19 December 2007,
being the strategic document including also the given section of the highway D4 was not the subject of the
assessment of the impact on environment, in particular in disaccord with the stipulations of the Act No. 24/2006
Coll.
Since the PPVDRC as the strategic document was not the subject of the assessment of the impacts on environment,
the rights of the citizens affected by the given section of the highway D4 were breached too. For example, the
citizens, affected by the given section of the highway D4 could not submit their standpoints, comments within the
individual stages of the procedure - assessment of the impacts of the strategic document PPVDRC on environment,
as it is regulated for example in the Act No. 24/2006 Coll. and in addition, even the concerned villages had no
chance to express themselves, to deliver their opinions, to present their comments to the strategic document or the
scope of its assessment since such a procedure on the impact assessment did not take place.
The strategic document named "The Program of Preparation and Construction of Highways and Expressways for
2007-2013, or highways, roads, or their parts based on the strategic document may not be transformed to the lawful
texts of the drafts of the acts due to the illegality, lawless character of the strategic document and therefore the
highways, roads or their parts based on the strategic document may not be specified in the Act draft and the act
amending the Act No. 669/2007 Coll. and thus they may not evens stated in the Act No. 669í2007 Coll. and thus
they may not be stated also in the Act No.669/2007 Coll. as amended, despite that the above mentioned, the
highway D4 is projected in the Act No. 669/2007 Coll.
Furthermore, I quote from the comments part to the Ministry of Environment of the Slovak Republic with regards to
the Program of Preparation and Construction of Highway and Expressways for 2007-2010." ... I warn the person
presenting the material /MDPaT SR/ that the "Programs of Preparation and Construction of Highways and
Expressways for 2007-2010" is the strategic document with the national reach, and this it is the subject of
assessment pursuant to Article 17 of the Act No. 24/2006 Coll. on the assessment of the impacts on environment.
The assessment pursuant to the Act is important in particular in the case the funds from the structural funds of the
EU shall be requested for the funding of the construction of the projects stated in he presented material."... In the
case the strategic document comprising the given section of the highway D4 was subjected to the complex
assessment of impacts on environment pursuant to the Act No. 24/2006 Coll., such impact assessment would prove
the negative impact of the strategic document on the system of protected territories with the presence of priority
habitats and therefore the preparation of the given section of the highway D4 would have been terminated in that
stage, in particular with regards to the stipulation of Article 15 Para 5 of the Act No. 24/2006 Coll
In accordance with Article 15 Para 5 of the Act No. 24/2006 Coll., in the case the strategic document has a
negative impact on the system of protected territories with the presence of priority habitats or the habitats of priority
species, it might be approved only for the reasons regarding human health, public order, the security of the Slovak
Republic, the significant impact on the improvement of environment or when it relates to other urgent reasons
pursuant to the standpoint of the European Commissions with regards to the public interests under the condition of
the implementation of compensatory measures inevitable for the provision of protection and integrity of the
continuous system of protected territories .
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The strategic document, named the Program of Preparation and Construction of Highways and Expressways for
2007 - 2010, that comprises the given section of the highway D4 may not be approved for the reason of a negative
impact of the strategic document on the system of protected territories with the occurrence of priority habitats. And
the strategic document, named the Program of Preparation and Construction of Highways and Expressways for 2007
- 2010, comprising also the given section of the highway D4 does not meet any single enumerative condition
specified in Article 15 Para 5 of the Act No. 24/2006 Coll. for approval, as for the given section of the highway D4.
According to Article 103r of the Treaty on the European Communities, the protection and improvement of quality of
environment, including the protection of habitats, wild animals and wild plants, are the primary objective of the
general interest followed by the European Communities.
The public interest, the supreme public interest in the territory affected by the section of the highway D4, specified
in the PPVRC, is the protection of environment, the protection of human health, the protection of environmentally
sensitive and specially protected natural territories. PPVDRC, the section of the highway D4 stated in the PPVDRC
is inter alia in disaccord also with this public interest. The highway D4 may be lead on another route, different from
the route stated in the PPVDRC and such a different route should be used that would not be in disaccord with the
public interest.
The Resolution of the government of the Slovak Republic is not generally binding legal regulation. It is and
organisational act. The Resolutions of the government of the Slovak Republic No. 1007/2006 and 1084/2007 are
also the approving documents. This regards the sections of the Resolutions of the government of the Slovak
Republic designated as "government approves“by which the government of the Slovak Republic approved the
Operation Program of Transport and the PPVDRC. As long as they approved the lawless, illegal basic material, the
approving document shall be also lawless and illegal.
a/ The Resolution of the government of the Slovak Republic No. 1007/2006, approving the Operation Program
Transport 2007-2013 is illegal, lawless in particular with regards to the fact the procedure of the approval of the
OPT and the procedure of the assessment of impacts of the Operation Program Transport 2007-2013 on
environment i illegal and lawless.
b/ The Resolution of the government of the Slovak Republic No. 1084/2007, approving the Program of Preparation
and Construction of the Highways and Expressways for 2007-2010 is illegal and lawless in particular with regards
to;
- that the assessment of the impacts of strategic document named The Program of Preparation and Construction of
Highways and Expressways for 2007-2010 on environment did not take place pursuant to the Act No. 24/2006 Coll.
The strategic document PPVDRC was not subjected to the assessment of its impacts on environment prescribed y
the Act No. 24/2006 Coll.
The complex assessment of the impacts of strategic document named "The Program of Preparation and Construction
of Highways and Expressways for 2007-2010" comprising the given section of the highway D4 on environment
would show the strategic document has a negative impact on the protected territory system, with the presence of
priority habitats and the strategic document may not beapproved e.g. even pursuant to Article 15 Para 5 of the Act
No. 24/2006 Coll. since the strategic document, as for the given section of the highway D4, does not meet any of
the enumerative conditions specified in Article 15 Para 5 of the Act No. 24/2006 Coll. necessary for the approval of
the strategic document . It is given in details above.
6. The results of the assessment of the impacts of the highway D4 Ivanka North - Záhorská Bystrica shown they
preliminary foresee a significantly negative impact of variants 2a, 2b, 7a, 7b and 7c of the highway D4 during both
the construction and operation on the hydric regime of NATURA 2000 territory of SKUEV 0388 Vydrica with the
presence of priority habitats and priority species - see Table IV. 3 of the text Annex 4 to the given material.
7. The results of the assessment of the impacts of the highway D4 Ivanka North - Záhorská Bystrica proved the
negative impact of the variants 2a,2b,7a,7b,7c, SPL of the highway D4 during the construction and operation as for
the direct interference with the habitats, noise and light disturbance, collisions with vehicles, i.e. the killing of
animals on the NATURA 2000 territory of SKCHVU 014 Malé Karpaty (the Lesser Carpathians) - see Table IV.3.
of the text Annex 4 to the given material, while it is necessary to note the individual negative impacts assessed in
the Table would affect the given territory in a cumulative way, whereby it would come to higher degree of
significance of the overall negative impact of the highway D4 on this specially protected natural territory. While
also valuable habitats would be affected. In the case of its construction, the highway D4 would have the negative
impact on the integrity of the territory SKCHVÚ 014 Malé Karpaty (the Lesser Carpathians).
8. I consider the results of the assessment of the impacts of the highway D4 Ivanka North- Záhorská Bystrica,
variants 2a,2b,7a,7b,7c of the highway D4 on the NATURA 2000 territory of SKUEV 0279 Šúr given in the Table
IV.3 of the Annex 4 to the given material to be undervalued.
When comparing for example the assessment of the impacts of the highway D4 /variants 2a,2b,7a,7b,7c/ in the field
of "the change in immission characteristics", the Table IV.3 reads, as for the territory of SKUEV Šúr and SKUEV
Vydrica identically during the construction on both territories, namely "no impact" and the assessment during the
operation is almost identical, namely "the moderate negative impact" for Šúr and "very moderate negative impact"
for Vydrica, despite that the SKUEV Vydrica is located ca 3 kilometres to the SW from the central duct of the
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variants 2a,2b,7a,7b,7c and SKUEV Šúr is located ca 500 metres from the body of the highway D /variants
2a,2b,7a,7b,7c/, from the Vajnory tunnel, from the GSI Čierna voda and in the proximity of the GSI Ivanka north,
the GSI Rača and the portal of the Karpaty tunnel. In addition, the route of the highway D4 /variants 2a,2b,7a,7b,7c/
runs at the length of ca 2.5 kilometres almost in parallel with the Western boundary of the SKUEV Šúr and the
similar shall apply also to the collectors planed alongside the highway.. The following shall apply to the variants 2a,2b,7a,7b,7c of the highway D4.
From the point of view of the protection of ecosystems, the most significant ones are the emissions of NOx under
standard operation conditions and the Regulation No. 360/2010 Coll. on the quality of air as amended specified the
immission limit of 30µg/rn3/year for them. The given limit is directly specified for the protection of ecosystems -
see p. 11 - text Annex 5. 4 to the given material. Pursuant to Table C.III.3 on p. 139 of the given material - the
maximum concentration of NO2 - the calender year in the immediate proximity of the highway D4/i.e. to the
distance of 350 - 400 m/ under unfavourable dispersion conditions for the variants 2a,2b,7a,7b,7c is ca
23.4µg/m3/year for 2030. The value of 23.4µg/m3/year approaches the above stated limit value, while as it is stated
above, they come from the underestimated traffic and the underestimated emission factors in the calculation of
immission load. And thus also the immission load stated in the Table on p. 139 of the given material is
underestimated as for the highway D4, but despite that it approaches the limit value. In addition to N02 or NOxm
the territory of the SKUEV Šúr would be affected by the emissions of CO, C02, ozone, airborne dust PM10 and the
other pollutants coming from the traffic on the highway D4.
The noise from the highway D4 was not assessed for the territory of SKUEV Šúr in the given material, but on the
basis of the noise load stated in the given material at certain distances from the highway D4, the SKUEV Šúr would
be affected by disturbing and animal-stressing level of noise from the highway D4, during both the construction and
operation. In addition, the noise load in the given material is undervalued. It is given in details above. It is known
that hearing of some animals is more sensitive than hearing of people. And many animals avoid the noisy places. "In
general, we may state noise hamper the mutual communication, mating and hunting of animals". The end of the
quote - from the material named the Assessment Report - the Complementation for the Highway D4 Jarovce -
Ivanka North.
The impact of light smog on SKUEV Šúr was not assessed. It is clear that also the negative impact of the highway
D4 would interfere with SKUEV Šúr, in particular during the operation of the highway D4. This regards mainly the
lighting of bridges, GSI Čierna voda, GSI Rača and the Karpaty tunnel portal. The illumination would attract also
butterflies, beetles, insects that would be subsequently killed on the highway. The light smog has an unfavourable
impact for example on the migration and hunts of animals, e.g. ornithofauna. It would come to the fragmentation of
the habitats of animals, including specially protected species from SKUEV Šúr.
According to Table IV.3 of the text Annex 4 to the given material, they expect the moderate negative impact of the
construction and operation of the highway D4 on SKUEV Šúr as for the change in the hydric regime. The territory
of SKUEV Šúr would be attacked also by the introduction of invasive species from the vehicles driving on the
highway D4 planned alongside the SKUEV Šúr. In direct causal relation to the highway D4, it would come to the
deterioration of the condition of habitats in the SKUEV Šúr and the impairment of the functions of ecosystems. The
highway D4 would then act as a line obstruction, a barrier, namely in the period of its construction and operation.
The animals from the SKUEV Šúr would be killed on the highway in the case of the construction of the highway
D4.
The stipulations of the Council Directive 79/409/EEC of 3 April 1979 on the protection of wild birds /the Birds
Directive/ were not considered in the given material. This is one of the directives regulating the protection of species
on the territories of NATURA 2000. Pursuant to Article 1 Para 1 of the Birds Directive, the species mentioned in
Annex 1 shall be the subject to the special measures regarding the conservation of their habitats in order to assure
their survival and reproduction in the area of their distribution. Pursuant to Article 4 Para 2 of the Birds Directive,
while considering the need of the protection of species named in the Annex 1 and for this purpose the member
countries shall devote a special attention to the conservation of wetlands, in particular the wetlands of international
importance. The given implies the subject of protection are also the bird species named in Annex 1 to the Birds
Directive. And some bird species named in Annex 1 are located also on the territory of SKEV 0279 Šúr and they are
thus the subject of protection on the territory and the deterioration or condition or damage of their habitats by above
mentioned negative impacts of the highway D4 /variants 2a, 2b, 7a, 7b and 7c/ has a negative impact on the integrity
of the territory of SKUEV 0279 Šúr with the presence of priority habitats and priority species.
The above mentioned negative impacts of the highway D4 /variants 2a,2b,7a,7b,7c / would act during the
construction and operation concurrently, cumulatively and for a long time or permanently and they would induce the
reduction in biodiversity, i.e. the decrease in the count of species and the abundance of the species on the NATURA
2000 territory of SKUEV 0279 Šúr with the presence of priority habitats and priority species. 9. Pursuant to Article
38 Para 4, second sentence of the Act No. 24/2006 Coll. on the assessment of impacts on environment and on the
amendment and supplementation of some acts as amended, the construction of the highway D4 in variant 2a, 2b, 7a,
7b and 7c may not be approved. The compensation of negative impacts of the highway D4 with regards to the
stipulation of Article 38 Para 4 second sentence of the Act No. 24/2006 Coll. may not be considered since the
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negative impacts may not be admitted, i.e. the construction of the highway D4 may not be approved. The
stipulations of Article 6 of the Act No. 543/2002 Coll. on the protection of nature and landscape as amended do not
relate to the case dealing with the negative impact of the proposed activity on the integrity of NATURA 2000
territory with the presence of priority habitats or priority species. It is not possible to proceed pursuant to the
stipulations of Article 6 of the Act No. 543/2002 Coll. in the case of the highway D4 Ivanka North - Záhorská
Bystrica for the reason of it negative impact on the integrity of NATURAL 2000 territory with the presence of
priority habitats and priority species, since there is a special legal stipulation regulating especially the conservation
of priority habitats and priority species, and the stipulation is Article 38 Para 4 second sentence of the Act No.
24/2006 Coll. The priority habitats are a special group of habitats of European importance that are subject to the
special protection pursuant to Article 38 Para 4 second sentence of the Act No.24/2006 Coll. and pursuant to Article
6 Para 4 third sentence of the Council Directive No. 92/43/EEC of 21 May 1992 on the protection of habitats, wild
animals and wild plants / the Habitat Directive/. Pursuant t Article 38 Para 4 of the Act No. 24/2006 Coll., as long as
on the basis of the result of the assessment of the impacts the negative impact of the proposed activity on the
integrity of the territory of the system of protected territories is revealed from the point of view of the objectives of
its conservation and should there are no alternative solutions free from negative impact or as log as there are no such
solutions with smaller negative impact, the proposed activity may be permitted only for urgent reasons of higher
public interest and under the condition of compensatory measures imposed pursuant to a special regulation.
When priority habitats or priority species occur on the relevant territory, the proposed activity may be approved only
for such pressing reasons of higher public interest that regard the public health, public safety or the favourable
consequences of the principal interest for environment or as along as it relates to other urgent reasons of higher
public interest pursuant to the standpoint of the European Commission. The highway D4 is not any of the
enumerative reasons of the public interests stated in Article 38 Para 4 second sentence of the Act No. 24/2006 Coll.
According to Article 103 of the Treaty on the European Communities, the protection and improvement of quality of
environment, including the protection of habitats, wild animals and wild plants, are the primary objective of the
general interest followed by the European Communities. The public interest, the supreme public interest, is in this
case the protection of natural territories with the presence of priority habitats and priority species and the protection
of human health. The route of the highway D4 may be lead through another territory, different from the territory
intended in the material named "The Report on the Assessment of the Highway D4 Ivanka North - Záhorská
Bystrica", namely the route of the highway D4 may be lead in such a way the negative impacts of the highway
would not interfere with the residential zones and the specially protected natural territories.
With regards to the above, I suggest the Ministry of Environment of the Slovak Republic not to recommend any of
the variants of the highway D4 /2a,2b,7a,7b,7c,SPL/ in the given territory or to recommend the zero variant.
Ing. Peter Pokrivčák, Bratislava (letter of 25.5.2011)
Let me send the following comments to the public discussion on the report of the assessment of
the impact of the structure on environment held on 10 May 2011 at the Magistrate of the Capital
City of Bratislava.
1. The vertical adjustment of all presented variants considered the routing if the highway D4
under D1 in Ivanka North intersection. This intersection is the part of the assessment of the
highway section of D4 Jarovce - Ivanka North. In the case of the selection of such designed
intersection, I recommend to route the section of Ivanka North - Záhorská Bystrica pursuant to
variant 7b. The routing in this variant, as well as the intersection of highway D4 under D1 shall
have the least negative impact on environment, in particular in the cadastre of the village of
Vajnory.
2. In the case of the selection of variant with the intersection of the highway D4 above D1, I
recommend variant 7c in the section of Ivanka North - Záhorská Bystrica with the following
amendments in the next stages of project documentation:
Route the highway D4 from the intersection with D1 (above) as far as Čierna voda
intersection including on the flyover bridge. This solution shall have the least impact on
the protected territory around the Lisy Lake of all variants.
Change the vertical alignment in the Karpaty tunnel so that as little section as possible
would be drained to the Eastern portal. We warn that Šúr kanál has bad run-off conditions
even nowadays and in the case of the supply of a large amount of water from the tunnel,
in particular when digging it out, shall probably require the modification of the kanál or
the building of another one and the diversion of water to the Little Danube.
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Consider the possibility of bidirectional operation on the Western collector alongside the
highway in the section from Rača intersection as far as Ivanka North intersection.
In the next stages of the project documentation, it is necessary to respect the international
cycling route and its intersection with the proposed highway.
When designing the anti-noise measures on the highway D4, it shall be necessary to
respect the planned construction of CEPIT and individual residential buildings in
Nemecká dolina Valley.
3. The technical and economically demanding section with a long tunnel starts behind the Rača
intersection in the entire section of the proposed highway. Therefore I suggest to divide the
entire construction in further project preparation to Jarovce-Rača section and Rača-Záhorská
Bystrica section and to adapt the schedule of preparation and construction to the division.
Ing. Daniela Pyszková, Bratislava (letter of 20.5.2011) According to me, the presented Report on the Assessment of Impacts on Environment (the EIA Report)
for the given section of the highway D4 is, including all the annexes, made in an absolute concordance
with the Act No. 24/2006 Coll. as amended. Many its parts, e.g. noise study, dissipation study, have
above-standard level, the authors used also the results of foreign studies to the particular topic (the
relation between the air cleanliness and noise on public health, the impact of the operation of the
highways on environment pollution, etc.
The quality of the report was certainly affected also by the the fact that in addition to the own sources, the
person drawing up the report used the Feasibility and Expediency Study for the route of D4 Bratislava
Jarovce - Ivanka North - Stupava South - state border was used. SR/RR (provided for by the investor
NDS), in which all the requirements from the Assessment Scope were technically dealt with while
observing the basic environmental conditions, all the proposed highway locations were assessed in
particular from traffic and economics point of view. The study (Feasibility Study) is one of the basic
required materials in the EU countries when arranging the funding of construction from the EU funds and
the banking sector. The report is written comprehensibly, the graphic annexes are well arranged and
informative. I would like to clarify it a bit - pursuant to the Construction Act (Article 117 b), the planning
office for the issuance of the zoning and planning decision for highways and expressways is the Regional
Planning Office. In addition to the length of Karpaty tunnel, the assessed variants 2a, 2b, 7a, 7b and 7c
differ in the alternative designs of Ivanka North intersection (the highway D4 lead above or under the
highway D1 with the continuation in the dug out Vajnory tunnel), Rača intersection and the ending of the
Karpaty tunnel near Marianka. I positively assess that the "collectors" are designed bilaterally alongside
the highway, i.e. the unidirectional 2-lane roads connected to the highway through intersections to which
the existing and also newly built areas fro the proximity of the highway would connect, whereby all the
requirements for connection to highway would be met.
I agree with the results of the report, the variant 7c is the most suitable in all aspects:
- the crossing of D4 with D1 is more suitable since the routing of D4 in the notch and further in the dug
out Vajnory tunnel would represent the risk for a complex hydric regime in the given flatland territory,
the report proposes all the measures on the highway D4 for the protection of ground water, in relation to
the project of anti-flood protection of the entire territory that was elaborated within the residential area
construction in Čierna Voda,
- Karpaty tunnel was prolonged near Marianka by ca 550 m (dug out part), whereby the request of some
inhabitants of the village was fully met (Sitina tunnel is designed in a similar way on D2 in Bratislava,
where the excavated shifter part near SAV has the length of ca 100m.)
- It represents the least risks and the impact on rock environment when digging out the tunnel,
- it was proven that it was the most suitable also from the point of view of transport, interventions in the
protected territories, urbanisation and impacts on inhabitants, it belongs also to he least financially
demanding (despite that all of them are expensive) and economically efficient. The corridor of the
variants of D4 is stated in all villages affected by variants 2a, 2b, 7a, 7b and 7c, save Borinka. In addition,
the location of the highway has been in the planning scheme of Bratislava defined as the "zero circuit of
capacity road“for ca 20 years. From this aspect, the requirements of various groups of interest for the
change in the highway route seem to be unjustified. This regards mainly the owners of houses and other
structures in the proximity of the route of D4, the construction of which intensively took place recently
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and still continues, regardless the planning schemes and their binding sections.
The highway D4 is the structure in a public interest, with a significant positive impact on urban, regional
and international transport and for Bratislava probably the most important and long awaited road structure
ever. The part is in use - in Petržalka, the section of Záhorská Bystrica-Devínska Nová Ves is before
operation permit granting. That means the beginning and end of the assessed section of D4 are fixed and
they may not be changed.
For the given reasons, the variant of Senec - Pezinok - Lozorno is not and may not be the variant of the
highway D4. The requirement in the assessment scope to assess it as the equivalent route of D4 was non-
professional, unjustified and it uselessly increased the costs of the elaboration of technical and
environmental documentation. Finally, it is assessed as the worst one in the EIA report too. However, the
technical design and environmental assessment of the route could be used for the preparation of the
prospective interconnection of D1 Chorvátsky Grob and the road II/502 Pezinok having a regional
importance, in the investment activities of the Bratislava Self-government Region.
The report lucidly describes the fulfilment of specific conditions specified in the Assessment Scope, with
the reference to the relevant chapters and annexes with their detailed design.
I have a comment to the condition No. 19 "To elaborate detailed geological and hydrogeological survey
of the impact of the proposed activity on the regime of surface waters and the ground water flow rate in
particular in the tunnel sections and the section of the municipal part of Vajnory. The contractor correctly
state a separate geological and hydrogeological study was elaborated; the detailed survey shall follow in
the next stage of project preparation. There are experiences from the other highway sections, that such a
condition of the Assessment Scope is considered to be breached by various civil associations, since no
survey (bores) were done in the field. The NDS always explained that when the EIA report assesses
several routes it would not be possible to carry out the geological, financially very demanding, survey (in
particular in the mountainous terrain), but the base documents from Geofond, where the rock environment
of the entire Slovak Republic is mapped rather in details shall be used. The data are sufficient for the
selection of variants. The detailed geological and hydrogeological survey is carried out just for a single
resulting highway route, the directional and vertical adjustment is clarified on the basis of the detailed
terrain survey and all necessary surveys. The contractor of the GHP closely cooperates with the highway
designer who corrects the route if necessary pursuant to the partial results of the GHP. All this is the part
of the zoning and planning decision documentation, not the technical study, in which the variants are
proposed and assessed. The results of the terrain GHP are used in particular for the proposals of the
particular technical designs - the establishment of bridges, the method of tunnel construction, slope
stabilisation, draining, etc.
The ideal condition, common for example in Austria, England, Germany is that the EIA report assessed
just a single resulting location of the route and thus the EIA report is made in parallel with the zoning and
planning decision documentation under the close cooperation of all designers and survey makers, thus the
assessment and the proposal of the measures for the reduction of negative impacts may be more concrete
and detailed.
In the Slovak Republic, they followed this way on some sections of D1 - in Bratislava it was the structure
of Viedenská - Prístavný most bridge, the structures between Trenčín and Považská Bystrica, the sections
in the Liptov region. The resulting position of the highway was determined on the basis of the 1st stage of
the EIA.
I note it down for explanation since I suppose there can be similar opinions of the lay public or people
working in the other fields than the investment activity. The proposed measures are, according to me,
sufficient, yet I recommend small additions:
- The shape of Rača intersection in the resulting variant 7c is probably the most suitable in the given
rather built-up territory, but after the survey of the terrain, surveys, new discussions with the ŽSR, the
owners of buried services, etc. in the next stage of the project documentation it would be possible to
modify it.
- The anti-noise walls are designed at the height of 2-4 m. This may be modified on the basis of more
detailed noise study made within the zoning and planning decision documentation. However, in general
and based on the experience from the other highway sections, it is suitable to build them with a certain
reserve, thus higher, as long as it is bearable from statics point of view.
Note: the report states the increase in noise near Vajnory is caused by the traffic on the highway D1. This
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shall be dealt with by anti-noise walls within the regular extension of D1 of Bratislava - Trnava.
The highway D4 passes through rather complicated territory from the point of view of terrain, settlement
and many production and other areas, many engineering and transport networks, natural environment, etc.
Many opposing interests meet there, however its construction is inevitable from the traffic point of view,
as soon as possible. Therefore it is very important to smoothly continue with the preparation of particular
route that should be decided for within a short time on the basis of expert documentations and
standpoints. The justified comments and requirements of public, that should be taken into account
pursuant to the Act No. 24/2006 Coll. as amended, may be dealt with in the next stage of project
preparation. In no case, the polemics on the amendment or supplementation of the highway routes could
be admitted, according to me. I do not classify my standpoint as the expert one, but with regards to the
fact I carried out and managed the assessment process for highways and some expressways in the Slovak
Republic for the NDS (formerly the SSC and RD), I do not consider it to be layman’s standpoint.
Juraj Minarovič, Marianka (letter of 18.5.2011)
The standpoint to the Karpaty tunnel:
I. The recommended variant 7c reckons with the completion of the Karpaty tunnel at m 15.2. I
consider the place to be extremely unsuitable, despite that the NDS and EIA overstate the tunnel
runs on the surface for last 200 m and it would be covered. Unfortunately, from the point of view
of the inhabitants of the village, the most problematic section of the route starts exactly on km
15.2, where the highway should continue outside the tunnel. It approaches the residential zone
the most there. Therefore I suggest shifting the portal at least by 600-800 m to the West in order
to minimise the negative impacts on the lives of people.
II. At the same time, I draw an attention to and submit the principal objection to the location of
venting duct on the place of the Western portal. According to the dispersion study, the duct with
8-metre chimney should serve for the diversion of air pollutants from both tubes of the Western
part of the tunnel. This is the question of products from approximately 2.5 km section of the
tunnel! (The rest of air pollutants are taken away y central and Eastern chimney). It is a real
tragedy that this significant stationary source of imissions is planned to be placed at the
Western portal, again on the place where the highway approaches the family houses of the
inhabitants of Marianka the most..
Therefore I ask the NDS to shift the duct in the case of the non.-modified variant 7c to the East,
as far from the dwellings as possible, at least to the place where the tunnel comes out from the
mountain range to the surface.
After studying the dissipation study, I get the impression the material is elaborated tendentiously.
It intentionally suppresses and disparages the effect of venting chimney at the Western portal.
This can be seen in particular on Fig. 6 of the Annex t the dissipation study named
V7bc_section2_2030_NO2-1h, p. 34, showing the level of imissions in the proximity of the
Western portal. We can see here the distribution of pollution alongside the uncovered highway
section that is diluted in natural way.
However, it is not shown here and we cannot find the trustworthy explanation in any place of the
material, how the chimney would influence the quality of air, when it concentrates air pollutants
from 2.5 km highway section on one place and subsequently blows them to the air on that place.
The statement the air pollutants are ejected with the speed of 16 m/s and therefore their
concentration in the air may not be measured is unacceptable with regards to the height of the
chimney of just 8 m and to the quantity of harmful substances.
I state the daily volumes of exhaled products according to the dissipation study just for
illustration for Western portal, variant 7c: the compounds of NO - 70.6 kg/day, the compounds
of CO - 49.2 kg/day, etc. When taking into account the prevailing direction of wind fro Stupava,
the pollutants shall be directed towards the dwellings of Marianka inhabitants and the noise load
by the facility would not be negligible as well.
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On the basis of the given suspicions, I ask the Ministry of Environment of the Slovak Republic
to appoint the trustworthy and independent subject to make the alternative dissipation study or at
least to get verified the veracity of data in the presented material by such a subject, including the
observation and correctness of the methodological procedures used when compiling the
dissipation study.
Silvia Jančová, Viničné (letter of 18.5.2011)
I really like the system of the public discussion of large structures. At least a common man has
the possibility to get more information directly from the source. I got the impression at the public
discussion that no one needs this, no one wants this and there is no money for this. Of course, I
do not understand everything and certainly the given structure has any strategic importance.
Therefore I would like to ask, if it would be constructed by chance, to consistently deal with all
intersections with cycloroutes in the project already (e.g.: Rača - Pezinok) so that the cycling
routes would not be uselessly prolonged. I rather like the design of the underpass on
Dolnozemská street in Petržalka, not far from the horse racing track or the flyover above
Einsteinova street near Incheba.
However, it would be suitable to note the primary feature of well-functioning city is a pedestrian
movement and thus related mass transport. Therefore the further support of individual
automotive transport would be disserviceable for Bratislava. It may happen that the cars would
stop further development of our cities and country.
The principal sense of transport structures is shortening of distances. However, it is necessary to
realize they are also a great barrier causing slowing down. Individual transport is the biggest
problem of the cities. The greater space is earmarked for cars, the farther it is necessary to build
houses from communications and the longer are the distances for which the communications are
constructed. The longer distances, the strongest argumentation for further construction of faster
communications. The idea of absolute freedom of movement in a car around the city was
brought to its perfection in America, where 50% of the area of the city belongs to transport in
some towns and cities and they do not have pathways there.
The document mentioned the displacement of people to the countryside. I am of the opinion that
in this case this is the sub-urbanisation phase of the growth of Bratislava agglomeration. The
proof of this is also the urban way of the parcelling out the new development areas in the villages
near Bratislava and the travels of the inhabitants of the villages to work to Bratislava. Bratislava
slowly gets to its intensification phase of growth and it should deal with an efficient way of mass
transport within 10 years, since strong population years shall be at the age of secondary school
attendants and they would not be able to travel everywhere by car. But when clearing the roads
off the cars, we can find out that what we call transit today, is supplying in fact.
In general, they prefer the idiom - Europe without borders and thus we should not think of
Bratislava within the cadastre boundary. Bratislava today reaches as far as Trnava. So why not
making the bypass somewhere behind Trnava? Then the tunnel under the Carpathians needs not
to be so long. Thus the development in Trnava would be supported and the car flows would be
reversed.
Michal Radošinský, Bratislava (letter of 10.4.2011)
Being empowered by the co-owners of plots of land with No. 2176/5, 2176/7, 2190/9, 2192/10,
2824/9 and 2824/10 on the Deed of Ownership No. 2176 for district of Bratislava III, village of
BA - municipal part of Vajnory, in the cadastral territory of Vajnory, in the Land Registry at the
Cadastral Office, the Administration of Cadastre of the Capital City of the Slovak Republic,
Bratislava, I express the disagreement with the location of the structure - the bypass of the city of
Bratislava preliminary named D4, the part of the construction of which is planned on our plot of
land.
We energetically require to carry out the construction of the bypass and related structures outside
our plot of land, or provide us with an equivalent replacement plot of land!
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After bad experience from the period of socialism, when they erected the newly built road No.
502 on a part of our plot of land without our consent and without any compensation instead of
making it on the place of the old road and when hydromelioration kanál and retaining reservoir
was built on the other part, we express this our disapproval. During the construction of the
bypass of the city of Bratislava, preliminary named D4, according to the contemporary projects it
would come to the interventions in the hydromelioration kanál and the retaining reservoir.
We encounter similar behaviour even now, when the illegal procedures of the Magistrate of the
City of Bratislava is just the continuation in the socialist intents, when it lawlessly exploits our
property without a legal title. They do not even pay the rent for the exploitation of our property
despite that we have repeatedly asked for it and they even did not provide us with a replacement
plot of land, despite that we have repeatedly asked them to do so.
We are aware the city owns the plots of land in various locations, that should rather be used for
the remedy of legal injury of past and not to be sold. They should not misuse its position of the
strong one versus the weak one - "the common" people"
The city of Bratislava owns various equivalent plots of land that could be used for the exchange
for our plot of land used by the city, yet not it its possession. The city would not thus uselessly
incur secondary costs of rent! However, we can guess that when selling the plots of land
belonging to the city, the city quickly receives greater amount of money, while spending the
majority of them in non-efficient way on return, yet blinding many citizens this way.
The plot of land was inherited by us after our parents, was purchased by them for borrowed
money after the World War II so that we would not hunger, while we had to work hard with our
parents as labourers so that the loan could to be repaid since we were poor and they wanted us to
get better just a little bit.
Ing. Miroslav Majdlen, Levoča, E-mail of 10.5.2011
From amongst the presented variants, variant 7b is the most suitable with regards to the
respecting of repeated requirements, how the D4 should look like from the side of the
neighbouring villages (Vajnory, Chorvátsky Grob, Rača) and respecting the conditions of nature
conservation. However, as long as it would be possible to maximally enlarge the distance of the
course of the highway from Chorvátske rameno branch (Šúr) in this stage and to place the GSI
Rača at least 100 m more to the left, closer to Lagermax.
The next assessed variant that could be recommended is variant 7a with a possible shift towards
Lagermax as the previous variant 7b.
Thanks a lot for possible consideration of my comments.
Zdenka Augustínová, E-mail of 24.6.2011
Let me express also the individual opinion of the alternative route of D4 that should lead through
Marianka.
Marianka is a picturesque village being surrounded by forest to a large extent. The front part of
Marianka is open and thus when winds blow from this side, it is aerated. Just for the freshness of
the winds, they planned to build a sanatorium in Marianka for the treatment of respiratory
diseases of children from Bratislava. When they found out radon leaking from soil, the people
building in Marianka were recommended to insulate well their structures and to vent them well.
Yes, vent them well. Please, look at the proposed alternative closely - the section of the highway
on the territory of Marianka in minimally 6 m filling plus 3 m noise barrier. The filling with the
height of minimally 9 m in the area from where the active winds blow to Marianka is rather
insensitive approach of people drawing the highway plans showing no interest in the health of
people who should live in the close proximity of the highway they drawn. Thus, when I come
from the information presented at the meeting of citizens in Marianka, I come out with the result
the barrier would get Marianka to spatial isolation to a great extent, many houses will be in the
shadow of the barrier and Marianka has its problems even now, either with the leaking radon or
the overall venting capacity of the area of Marianka valley, that is developed more and more and
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people still burn solid fuels there. We really have enough our air pollutants. Just come and
measure them in right time.
I shall not write a lot, I just would like to support the official standpoint of the village of
Marianka and the civil association Malé Karpaty proposing that if there is no other possibility
and the highway should be routed by the village of Marianka, I am for the prolongation of the
tunnel as close as possible to already built intersection that was constructed without the
consulting the village of Marianka.
I would really like to appeal to the good sense of people having the destiny of the inhabitants of
Marianka in their hands to have elaborated serious studies on the wide impact on history - the
city of pilgrimage, nature - the breaking of the paths used by forest game, recreation - the
cycloroute of the European importance, the health of people - radon, air pollutants, noise and last
but not least the reduced comfort of living - 9 m barrier, let’s call it anti-wind anyway at the
distance of ca 400 m around the village.
The highway should serve in particular for the relief of transit transport, not the urban one, as it
was said by someone here. The international interconnection certainly plays a major role here
(the EU ma help with the funds), let Volkswagen contribute to it, its interest is to transport cargo
from their plant in Martin faster and cheaper.
Finally, I would like to stress out that when the highway would be constructed as it is requested
by citizens, so small Slovakia may be proud on the world that we got among the most developed
countries of the world with a highway built in a tunnel with the contribution of an open dialogue
with people.
Petitions
Petition for leading circular road D4 in variant 7b through the covered tunnel alongside
Vajnory
On 6 September 2011, the citizens of Vajnory submitted a petition to the Ministry of
Environment SR for leading highway D4 in variant 7b (a tunnel). The petition was submitted by
the Mayor of Vajnory, Bratislava, and a representative of the petition committee, Ján Mrva,
directly to the Minister, József Nagy. The full wording of the petition is as follows:
"The citizens of Bratislava - Vajnory categorically disagree with a solution to leading the circular
road D4 other than variant 7b, with a sub-surface - covered - tunnel next to Vajnory. Other
variants, including variant 7c preferred by the Národná Diaľničná (National Highway Company)
are unacceptable and will have an exceptionally negative impact upon the appearance - scenery -
of the countryside and will irreversibly alter its nature. The surface variant on an embankment
will have a negative impact upon the mental health of the inhabitants and upon the already poor
standard of housing. The structural components of the new D4 with a bridge over D1 at a height
of 15m and then a steep incline down to an 8m embankment which should be constant along the
whole area of Vajnory is not acceptable to the inhabitants of Bratislava - Vajnory. The
inhabitants of Bratislava - Vajnory only agree with variant 7b, or with a modified version from a
sub-surface tunnel to one laid on the terrain (if the hydrological study shows embedding to be an
unsuitable solution due to the flow of ground water), with a covered tunnel from 0.9 to 2.3 km.
We require our petition to be accepted during the decision-making of the Ministry of
Environment SR in Bratislava and we require the investor - National Highway Company - to
include it in the project documentation for area management."
The petition was signed by 870 citizens
Petition for changing the route of highway D4
The petition for changing the route of highway D4 was submitted by a representative from the
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petition committee and the Member of Bratislava Region Parliament, Anna Zemanová, to the
Chairman of the Bratislava Region, Pavol Frešo. We could not obtain further information about
the petition.
The "Let's Save Marianka and its surroundings" petition
The public initiative, "Let's Save Marianka", is organising a petition against the building of the
Mariánsky tunnel. The petition is unfinished and its full wording is as follows:
We, undersigned citizens of the Slovak Republic, are aware that the construction of the highway
section "Highway D4, Ivanka section, north - Záhorská Bystrica", further also the "Mariánsky
tunnel"
shall permanently and irreversibly devalue the picturesque valley between Záhorská
Bystrica, Marianka and Stupava where, until now, the three mentioned villages have
lived in peace;
shall permanently halt development and the unique atmosphere of Marianka - the oldest
pilgrimage place in Slovakia - wall suffer;
the democratically elected government wishes to do what the Communists failed to do in
40 years of totalitarian regime - to destroy the character, attractiveness and future of
Marianka;
the entire area of Marianka and Záhorská Bystrica will be contaminated by noise,
emissions and vibrations spreading from the Mariánsky tunnel, needlessly and
senselessly located in the close vicinity of people's dwellings;
the flora and fauna of the Little Carpathians Protected Landscape Area, ground water as
well as the legendary, the holy Mariánsky spring and the whole ecosystem will suffer;
the panorama of the Marianka and Záhorská Bystrica valley with Pajštún Castle and the
horizon of the Little Carpathians will be destroyed by the Mariánsky tunnel, insensitively
and arrogantly situated high above the terrain, therefore losing its natural magic and
recreation potential for inhabitants, cyclists, tourists, pilgrims and gardeners;
does not resolve the significant traffic problem in Bratislava and its surroundings;
although highway bypass D4 is very important in terms of traffic, there is no persuasive
specialist reasoning for building the Mariánsky tunnel as part of highway bypass D4;
will crown the unprecedented, unprofessional and illegal procedure in the preparation of
the Mariánsky tunnel; during its preparation, Slovak and international standards and
agreements were seriously breached;
we require
Iveta Radičová, Prime Minister of the Slovak Republic
Richard Sulík, Chairman of the National Council of the Slovak Republic
Ján Fígeľ, Minister for Transport, Construction and Regional Development of the Slovak
Republic
József Nagy, Minister of Environment of the Slovak Republic
a) to immediately halt preparation works on the Mariánsky tunnel (highway section: "Highway
D4, Ivanka section, north – Záhorská Bystrica“);
b) to investigate and prove the priority, justification, feasibility and public interest in
implementing the Mariánsky tunnel (highway section: "Highway D4, Ivanka section, north –
Záhorská Bystrica“) using a renowned, independent international institution;
c) to proceed in planning the development of motorways and the road network, their preparation
and implementation in compliance with the laws of the Slovak Republic and international
legislation related to this issue, as well as in compliance with the justifiable interests of the
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citizens of the Slovak Republic and in compliance with the protection of nature and the
countryside;
since, in relation to the Mariánsky tunnel
a) the legal process for evaluating the predicted impact upon the environment was not
implemented and adhered to in the strategic document "Programme of the preparation and
construction of motorways and highways for 2007 - 2010" in compliance with Act No. 24/2006
coll. on assessing environmental impacts, which is in contradiction with the abovementioned
Act, with the Council Directive 85/337/EC of 27 June 1985 on assessing the environment impact
of some public and private projects as well as in contradiction with the Aahus Convention which
guarantees the public access to information about the environment, participation in the decision-
making process and access to justice in environmental issues;
b) there is no relevant document proving the execution of research and development for the road
infrastructure including proven justification for the construction and future use, nor objectively
obtained results of such research and development for the road infrastructure, and such a
procedure in the matter of designing roads without the stated documentation and research is a
violation of Act No. 135/1961 coll. on roads (the Road Act) as amended;
c) for the reasons stated in points a) and b), there is reasonable concern that the Constitutional
Act No. 357/2004 coll. on the Protection of Public Interest in the Performance of Offices by
Public Officials as amended was violated;
d) for the reasons stated in points a), b) and c), there is reasonable concern that non-compliance
with legal procedures is an act in strict contradiction to Act No. 523/2004 coll. on the Budget
Rules of the Public Service as amended.
The petition was prepared and submitted by a petition committee consisting of the following
persons:
1. Juraj Turčáni, Krasinského 5, 821 04 Bratislava