In response to EcoLur's letter dated on May 5, 2021, RA Environment Ministry informs, "According to state expert opinion BP-00006 issued by “Environmental Impact Assessment Center" SNCO on July 17, 2019, to the environmental impact assessment report of "Masrik 1" solar station, solid and liquid wastes generated during the corridor planning in the construction of a photovoltaic (PV) station and an overhead line (OH), used engine oils, used tires, will be stored in a concrete-covered area before delivery, and construction waste will be transported to landfills provided by Mets Masrik and Geghamasar Municipalities in Gegharkunik Region.
A special area will be provided for fuel storage, which will have a concrete platform and a drainage collection system. Additional measures aimed at reduction and mitigation environmental impact are envisaged. On May 30, 2019, Armenia Renewable Resources and Energy Efficiency Fund carried out additional field biodiversity studies within the framework of the Masrik 1 solar power plant construction project in Mets Masrik and Geghamasar in Gegharkunik Region, particularly, to receive thorough information on the areas included in “Emerald” Environmental Network.
Based on the results of discussions with international experts conducting the assessment of the network areas and the countries concerned, in 2017 it was decided to conduct additional studies through an expert group to review the proposed potential area boundaries. The working group in 2019 submitted proposals to the Ministry of Environment on the optimization of "Emerald" network. According to these proposals, Gegharkunik region includes 4 potential areas of "Emerald" network with a total area of 82421.8 hectares, therefore the area allocated to the solar power plant is beyond the borders of "Emerald" network in Gegharkunik region."
This response, however, does not contain any information on how the solar panels/batteries should be disposed of after the expiration date. RA Ministry of Territorial Administration and Infrastructure does not have a clear response. In particular, the Ministry’s Energy Department informs that there are currently no documents or standards for the disposal of solar energy waste.
"It is clear that we are thinking about creating conditions for utilization. We are currently working in that direction, but there is no document or standard yet. But we definitely understand the problem. The Energy Law also states that the owner is required to provide green space after converting the plant into energy. We must also create conditions for all that to happen," Ministry’s Energy Department Head Tigran Melkonyan said.
Reminder: EcoLur’s letter addressed to the ministry particularly outlines:
"Dear Mr. Minister,
In 2019, RA Environment Ministry gave a positive conclusion to the "Environmental Impact Assessment Report of Masrik-1 Solar Power Station".
It should be noted that, according to the IFC (WB) Operational Policy (OP) 4.01 on Environmental Assessment, which is co-financing the Project, this project is classified as Category B, therefore it requires an EIA Report and Environmental Management Plan according to the World Bank guidelines. The other co-lender, the European Bank for Reconstruction and Development, has the same approaches.
Requirement 1. Environmental and Social Impact Assessment and Their Management
Requirement 3. Resource Efficiency, Pollution Control and Prevention
Requirement 6. Biodiversity Conservation and Sustainable Management of Living Natural Resources
Published in 2016 by the International Renewable Energy Agency (IRENA) and the International Energy Agency (IEA), “End-of-Life Management. Solar Photovoltaic Panels" study states that about 1.7 - 1.8 million tons of photovoltaic waste (cumulative) will be generated worldwide by 2030. By 2050, the volume of expired solar panels will increase to about 60-78 million tons. Recycling this amount of waste is a new challenge for the environment.
It should be noted that the conclusion of the Environmental Impact Assessment BP-0000610 issued to the environmental impact assessment report of Masrik-1 solar power station on 17.07.2019 does not ensure the fulfillment of the above-mentioned requirements and is not in line with the direction of "green" economy adopted by our country.
In particular, the environmental management plan of Masrik-1 solar power station, submitted by “FRV Masrik” CJSC, which received a positive expert opinion, does not even mention about the recycling and utilization of the solar panels during the project implementation, as well as after its completion, the funds required for their implementation, sources of funding and people in charge.
In addition, the conclusion of Masrik-1 Environmental Impact Assessment Report states as an expert requirement that additional biodiversity field research should be conducted by Armenia Renewable Resources and Energy Efficiency Fund in the project area.
After the completion of these studies, it should be submitted to Environment Ministry in case of overlap of the areas allocated for the planned activities and the areas included in the "Emerald" ecological network, the implementation of works in those areas should be excluded.
Pursuant to Article 6 of RA Law on Freedom of Information, please provide information on the following:
1. What measures does the Ministry envisage in the project for the inclusion of the processes of recycling and utilization of solar panels in the project, and the inclusion of financial expenses in the environmental management plan envisaged for that purpose?
2. Has the envisaged additional biodiversity field research been accomplished, if yes, whether or not there are overlaps of areas included in “Emerald” network.
May 14, 2021 at 16:39