Several NGOs claimed the construction required separate permitting, as well as public participation and assessment procedures, under the EIA Directive and the UNECE Aarhus and Espoo conventions, arguing that the work should legally be considered a new project. However, obligations under the EIA Directive took effect at the time of accession, on 1 May 2004. Given that the project was initiated, authorised and partly built prior to accession, the EIA Directive is not applicable. Nevertheless, the Slovak authorities informed the Commission that they had voluntarily initiated a new EIA procedure for units 3 and 4 before issuing the permits for commissioning and operations. Source: UNECE, 2010. However, the current SEA legislation contains a number of shortcomings.