Correspondence with "FRV Masrik" Company on Construction of Masrik-1 Solar Power Station

Correspondence with "FRV Masrik" Company on Construction of Masrik-1 Solar Power Station

EcoLur has sent a letter regarding the construction project of "Masrik-1" solar photovoltaic station to the project implementing company "FRV Masrik". The letter says,

“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 - A. 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.

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.”

In reply, FRV Masrik CJSC General Manager Tristan Higuero and Authorised Representative Deniz Saidov wrote in their letter dated on 21 December 2022:

Contrary to certain allegations in the Ecolur Letter, the implementation of the Masrik-1 Solar photovoltaic power plant project (the “Project”) has been ongoing since the establishment of the project company, including works on the design, permitting, procurement and construction of the Project. This being said, the tension and periodic armed clashes on the Armenian-Azerbaijani border have caused delays in the construction works, which resulted in the extension of the construction period for the Project until September 1, 2023.

The project company was granted the EIA Expertise Conclusion on July 17, 2019, which is in full force and effect as of the date of this Letter since the project company never ceased its activities aimed at implementing the Project.

We note that the Ministry of Environment Letter restates certain provisions of the Armenian Law on Environmental Impact Assessment and Expertise and is for information purposes only. It should be considered for reference, without creating specific legal consequences.

Regarding the other questions, you raised:

Management of hazardous electronic waste.

As the first solar park to be developed in Armenia, the project’s strategy is to reduce the volume of e-waste throughout its operations by extending the lifetime of any product or its constituent parts through repair, reuse and refurbishment. Unsalvageable solar panels and components will be stored at an on-site Hazardous Waste Storage Facility before sustainable treatment/disposal options are either developed on a country-level or sourced externally.

Project site and loss of fertile soil.

As part of the project’s due diligence, the land of the project site was carefully assessed it found to be ineffective pastureland due to over-grazing, soil salinity and compaction. Land acquisition was a voluntary land transaction in which the community provided the land according to local legislation. The community has been paid in full based on the assessed (by a Certified Valuator) or cadastral value of the land.

Electric and magnetic fields.

Electric and magnetic fields will be mainly generated under the overhead transmission line (OHL). The route of OHL was selected considering the proximity to residential properties. None of the properties are within buffer corridor as prescribed by local regulations.


Emerald Network candidate area.

Masrik Solar project obtained a letter from the Ministry of Environment (MoE) in 2019 confirming that the project site is not part of proposed Emerald area. The MoE informed the project Sponsor and Lenders that a Research Group on the Creation of a Network in Armenia developed and submitted to the Ministry of Environment, an Optimization Proposal of the network, according to which only some Sevan National Park sites and the small area of slopes of the middle section of the Geghama Ridge were proposed as potential Network Areas. Land plot allocated to the solar power plant is not included within the Network.

This decision was confirmed by the findings of field surveys of the area, which IFC requested for Masrik 1 Plant. Based on the outcomes of the surveys, the project area is a highly modified habitat traditionally used for grazing. There are no plant or animal species which may become extinct or are endangered, and the plant species are common and typical of pastures.

We trust that the information provided helps answers the questions and concerns Ecolur has expressed. We thank you again for your valuable engagement on this project. We would also like to note that FRV Masrik has also set up mechanisms for engaging with project stakeholders and all those issues were discussed with stakeholders during the EIA impact assessment carried out for the Project, as well as during the six (6) public discussions held on the subject.”

December 29, 2022 at 11:17