EcoLur has sent a letter to Bruno Marinho, a representative of FRV company implementing “Masrik-1” solar power station construction project, which says:
“Dear Mr. Bruno Marinho,
Due to the Armenian-Azerbaijani military conflict that started in 2020, the construction of "Masrik-1" solar photovoltaic plant has been stopped for two years, because the area is located in a dangerous border zone that is exposed to gunfire. The construction of the station was supposed to be accomplished on July 1, 2022. According to RA Government's resolution N 997-A dated on June 30, 2022, the construction period of the station was extended until September 1, 2023. However, the environmental assessment of the construction of "Masrik-1" solar photovoltaic plant has lost its validity, as RA Deputy Environment Minister Tigran Gabrielyan informed to "EcoLur" Informational NGO with his letter N 3/07.4/13313 dated on 05.10.2022.
Therefore, in accordance with RA legislation, a new EIA is required for the implementation of the construction project of "Masrik-1" solar photovoltaic plant.
EcoLur has studied the EIA, ESIA, and environmental assessment report submitted by FRV company, which was issued in 2019. Our study revealed the following:
- Both documents specify project categories. ESIA specified the project as Category B, whereas the expert assessment report indicates a more stringent category - Photovoltaic panel numbers are also different. The ESIA lists "just over 180,000 PV panels", whereas the EIA mentions another figure -165,368.
- The EIA states that the station will be built on fertile land, where the humus thickness reaches 70 cm to 1 m, but no document has assessed the economic value of the land loss and the possibility of compensation. Both documents lack full information on what will be done or how electronic wastes will be managed, which is a big problem because Armenia still does not have a regulatory framework for managing waste generated by solar energy.
- The EIA report assesses the long-term, indirect impact of the electric and magnetic field on the public and employees during the operation of "Masrik-1" solar plant. It is not specified what effect this field can have on human health.
- On the website of the Bern Convention, the candidate area of "Emerald" network is the entire area of "Sevan" National Park with its 489,839.8 hectares, which also includes the construction area of "Masrik-1" station.
RA Environment Ministry has not yet submitted the updated, reduced list of Armenia's "Emerald Network" candidate area to the Berne Convention Bureau, which means that "Masrik-1" station will be built in "Emerald" network candidate area. There is no reference to this in the documents submitted by FRV.
- Mets Masrik community, where the station will be built, as a result of community consolidation, has been included in Vardenis consolidated community since 2021. It means that it is necessary to take this circumstance into account and ensure the full participation of the interested population in the public hearings in the new EIA process.
Dear Mr. Bruno Marinho,
We can assure you that we welcome the development of solar energy in Armenia, including the construction of "Masrik-1" solar plant. We believe that it should be built on non-agricultural land and the project should take into account all risks and provide measures for their elimination, thus keeping high the environmental and social standards and reputation of both FRV company and the international financial institutions that are the investors of this Project.
We suggest to consider the problems presented by us when conducting a new EIA. We are ready for constructive dialogue and the discussion of problems”.
December 05, 2022 at 15:33