EcoLur’s Comments on Governmental New Program In Terms of Environmental Priorities

EcoLur’s Comments on Governmental New Program In Terms of Environmental Priorities


The Armenian Government has presented a new programme, which also has an environmental section. The programme describes certain actions and implementation schedules with a focus on environmental priorities.

EcoLur is presenting its comments and proposals for programme implementation. Whether the government will be able to solve the main problems related with rational and safe use of natural resources, environmental and social conflicts and contradictions existing in ecological hot spots. The following fact should be taken into consideration that it’s getting more and more difficult to solve problems accumulated during years.

About preservation of ecological balance of Lake Sevan: Lake Sevan is a strategic object and a national environmental priority in Armenia with a status laid down in RA Law “On Lake Sevan”. Public expressed their concerns several times that RA Law “On Lake Sevan” determining the conservation of its ecosystem, maybe amended as a result of change in policy and will stop serving as a legislative guarantee for Lake Sevan. Such attempts were made several times and we hope that the new governmental will undertake guarantees for the conservation of Lake Sevan.

The list of lake problems is huge, but the main problems are as follows: increase in lake level up to 1903.5 meter above sea level and not permitting water outlets out of Lake Sevan more than statutory one. Then the problem of contamination with sewage and industrial flows: the programme mentions cleaning of sewage, but this matter shall be scrutinized in regard with Lake Sevan. As it’s known, cleaning structures in three town in Sevan basin don’t decontaminate sewage and don’t hinder inflow of water from the river saturated with heavy metals. Environmental assessment of Lake Sevan pollution shall be given due to mining activities and to include data not only on water, but also on bed deposits in the rivers flowing into Lake Sevan, where heavy metals and aggressive compounds are accumulated.

The annual budget funding on Lake Sevan shall envisage also funding for such sort of studies.

The problems of SHPPs constructed on the river flowing into Lake Sevan shall be solved in urgent manner, as they eliminate endemic fish species characteristic of Sevan basin biodiversity.

Monitoring of pollution Lake Sevan with artificial forage containing nitrogen and phosphorus and wastes shall be carried out, which result from the Program on Recovery and Development of Sevan Trout Reserves using cage net methodology for fish breeding and ensure publication of monitoring findings.

The matter of increase in effectiveness of environmental control with the help of new technologies has been included in the new governmental programme and implementation schedule is 2017. It should be noted that the former government imposed a ban on planned inspections of business entities, which decreased the effectiveness of the performance of environmental obligations and led to accumulation of violations. It’s still a question whether or not the new government will prolong this ban, which is in force till the end of 2016. Then, the matter of funding environmental supervision system with new technologies is left open and we propose that the government is willing to fund it at the expense of budgetary funds.
To enhance the control over the existing objects of alternative energy, particularly to set online control over the environmental flow of SHPPs. To develop a national strategy on SHPPs, particularly taking into consideration the mass development of micro power stations.
What about the expansion of strictly protected areas, including the establishment of Jermuk National Park. The problem is that the new strictly protected area, as well as newly-founded ones, for example, Arevik National Park, shall comply with the requirements laid down in international and national environmental legislation, particularly what about ensuring safety of habitats of endemic species or species on verge of extinction.

Open pit mining supposes carrying out explosions and complete destruction of habitats, elimination of migration corridors, which are directly not included into strictly protected areas of nature, but also a part of habitats. In case of Jermuk or Arevik, these requirement are violated, so an ad hoc assessment of mining impact on Arevik and Jermuk strictly protected areas of nature shall be carried out and to include it in their development and expansion strategies, as well as concepts on green economy.

To ensure the principles of open governance, transparency and accountability in the implementation of the new governmental programme, as well as to ensure involvement of active civil society in decision-making process.

October 21, 2016 at 18:35