EcoLur applied to Environment Ministry proposing to revoke expert assessment opinion BP 000061 of the construction of "Masrik-1" solar photovoltaic (PV) power plant, as the term of the opinion has expired.
EcoLur's letter says:
"On 17.07.2019, Environment Ministry issued positive expert assessment conclusion BP 000061 of the environmental impact assessment report of "Masrik-1" solar plant.
Due to the COVID-19 pandemic and the 44-day war, construction of the station was not completed until 2022. The construction completion date of "Masrik-1" solar photovoltaic station has been extended by more than a year. The construction of the station was supposed to be completed on July 1, 2022. However, it has not yet been built. According to RA Government resolution N 997-A of June 30, 2022, the construction period of the station was extended until September 1, 2023.
In this case, the requirement of Article 20 (7) of RA Law "Environmental Impact Assessment and Expertise" did not apply, according to which the expert opinion loses its validity if the implementation of the planned activity does not start within one year after the expert opinion is issued.
It should be noted that the environmental impact assessment report of "Masrik-1" solar plant did not consider a number of risks that could become a serious threat to the environment during the operation of the plant.
According to the EIA report of "Masrik-1" solar plant, 165,368 photovoltaic panels with a capacity of 375 W each, and 12 transformers will be installed in the plant. There is no provision for storage, recycling or transport of decommissioned photovoltaic panels as electronic hazardous waste. It is not specified how much waste the decommissioned panels and carriers will generate.
A total of 18,129 m3 of land will be removed. It will be stored at the edge of the solar plant area.
It is unacceptable to build a solar plant on such fertile land in the area of 128.3 ha and lose the fertile land that is so necessary for agriculture. The economic damage of losing that fertile land has not been estimated, and how much the damage caused will outweigh the economic benefit of building a solar plant in that area.
In the EIA report, the impact of the electric and magnetic field on the public and employees during the operation of the "Masrik-1" solar plant was assessed as long-term and indirect. It is not specified what effect this field can have on human health.
The positive expert assessment conclusion BP 000061 issued by RA Environment Ministry dated on 17.07.2019, there is no expert assessment requirement regarding the settlement of these problems.
Considering these problems and the fact that the term of positive expert assessment conclusion BP 000061 for the construction of the "Masrik-1" solar plant has expired, we propose to revoke positive expert assessment conclusion BP 000061. The construction project of "Masrik-1" solar plant must undergo a new examination, where all risks will be considered and appropriate solutions will be provided."
In response, RA Environment deputy Minister Tigran Gabrielyan informed by letter N 3/07.4/13313 dated on 05.10.2022. "In response to your letter dated on September 9, 2022, I would like to inform you that according to RA Law "On Environmental Impact Assessment and Expertise" (hereinafter referred to as the Law), the expert assessment opinion laid down in Article 20(7) loses its validity if the planned activity does not commence within one year after the issuance of expert assessment opinion." An expert assessment opinion is considered invalid by law. According to Clause 6 of the same article of the law, without a positive expert assessment opinion, the adoption of the founding document or the implementation of the planned activity is prohibited."
It should be noted that "FRV Masrik" CJSC, which implements the construction project of "Masrik-1" solar plant, applied to Department of Water Resources Management of Environment Ministry for household-domestic /economic/ underground water use permit in the amount of 0.1354 l/s in the administrative area of Mets Masrik village, Vardenis community, Gegharkunik Region. The discussion of the document will take place at 16:00 on October 10, 2022, at Environment Ministry (Government Building 3, 5th floor, room 541).
October 10, 2022 at 12:48