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“Regional Monitoring Institute” NGO continues demanding from the financial institutions funding the project on Kapan Town water supply system improvement to undertake responsibility for the program. This material refers to the recent correspondence of the European Bank for Reconstruction and Development and “Regional Monitoring Institute” NGO on the problem with water supply in Kapan Town.
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"To Mr. Mark Davis, Head of EBRD RO Yerevan
Dear Mr. Davis,
I would like to express my contentment with respect to your quick response. It is worth mentioning that the response of “Armenian Water and Sewerage Company” CJSC regarding the letter submitted to you on the water supply system of Kapan was published in “Ecolur” news media website on 20.10.2015 and it mainly has the same content as the data provided by you. I consider that you could have at least conducted independent study on the raised issues instead of simply citing the non-reliable information provided by “Armenian Water and Sewerage Company” CJSC. Reaffirming my approach to the fact that the information presented in your letter does not correspond to the reality I would like to submit
to you certain evidence on the verity of the identified information through the attached documents. I’m prepared to submit additional facts and grounds on the below mentioned issues, if need be.
1. There is false information regarding the fact that local non-governmental organizations do not reveal interest to the implemented activities. In fact, we have regularly addressed various requests and complaints on the gaps of the water supply network construction work carried out by “Armenian Water and Sewerage Company” CJSC both to the management of the “Armenian Water and Sewerage
Company” CJSC and to the Municipality of Kapan. In response the company just provided a disrespectful note suggesting acquiring the required information from various websites. Attached you can find the
copies of the sent requests and their responses which can prove that the required information is not available on the mentioned websites.
2. Many times we have applied to the Mayor of Kapan with the request to provide us with the copy of the water supply contract signed between the Kapan community and “Armenian Water and Sewerage Company” CJSC , however the authorities of the community refused to provide it reasoning that it is a “non-standard” contract and cannot be provided to the public. It should be noted, however, that RA legislation does not provide for such type of contract. From our point of view the contract is not provided due to certain corruption risks (see the attached notes).
3. There are essential deviations (poor quality pipelines, non-professional organization of works, etc.) in the issues regarding water supply and the quality of construction works. Certain complaints referring to the noted issues have been raised many times during the discussions held particularly in the Municipality of Kapan (see attached the video record). We have also applied to the Asian Development Bank with respect to the quality of the construction works. The correspondences with the representatives of the ADB are continuing.
4. A great many of violations referring to the water quality have been registered. You can be informed of the presented official documents on more than 155 deviations from the water quality standards of Kapan.
5. Furthermore, in the course of the project implementation on the improvement of water supply network the statutory procedures for the environmental impact assessment were not ensured which resulted in the violation of public norms stipulated by national legislation and international agreements (the population rights of the affected communities in accordance with the Aarhus Convention). As prescribed by the national legislation and by international agreements with the involvement of Armenia (Aarhus Convention, Kiev protocol, etc.) public participation is to be ensured in decision-making processes on environmental issues at the earliest stage which is implemented through public discussions in accordance with law. The present law requirement was totally violated. We believe that the project’s
complete failure is due to the fact of not ensuring public participation.
The poor quality of the implemented activities and non-transparent actions provide grounds for assuming that there could be corruption risks in the present process. Unfortunately, we can conclude from your letter that EBRD reveals non-professional commitment to the issues of national security like the issue of drinking water supply. We recommend you to properly assess the project implementation course and the results. We would also like to inform you that we will be consistent in raising the identified violations in court and international instances. You can also apply to us with the aim of obtaining additional information with regard to the present project implementation. We are prepared to provide true and factually grounded information with great pleasure.
You can find attached certain documents proving the verity of the raised issues: our correspondences with the Municipality of Kapan and “Armenian Water and Sewerage Company” CJSC, as well as the data on the drinking water quality provided by respective state authorities. In order to acquire more comprehensive picture of the project violations, we recommend you once again to have a visit to Kapan in order to meet with the representatives of the local civil society.
Best regards,
Arshavir Khalapyan
President of “Regional Monitoring Institute” NGO"
December 22, 2015 at 15:25