"EcoLur" Information NGO addressed RA Environment Minister Hakob Simidyan proposing to revoke the positive expert assessment conclusion issued for the construction of "Masrik-1" solar plant due to the expiry of the latter and failure to include solutions regarding a number of risks in the EIA report of the plant. The station is being built by "EFARVI MASRIK" CJSC in Mets Masrik settlement of Vardenis consolidated community, Gegharkunik Region.
EcoLur's letter says:
"On 17.07.2019, Environment Ministry issued positive expert assessment conclusion BP 000061 of the environmental impact assessment report of "Masrik-1" solar plant.
Due to the COVID-19 pandemic and the 44-day war, construction of the station was not completed until 2022. The construction completion date of "Masrik-1" solar photovoltaic station has been extended by more than a year. The construction of the station was supposed to be completed on July 1, 2022. However, it has not yet been built. According to RA Government resolution N 997-A of June 30, 2022, the construction period of the station was extended until September 1, 2023.
In this case, the requirement of Article 20 (7) of RA Law "Environmental Impact Assessment and Expertise" did not apply, according to which the expert opinion loses its validity if the implementation of the planned activity does not start within one year after the expert opinion is issued.
It should be noted that the environmental impact assessment report of "Masrik-1" solar plant did not consider a number of risks that could become a serious threat to the environment during the operation of the plant.
According to the EIA report of "Masrik-1" solar plant, 165,368 photovoltaic panels with a capacity of 375 W each, and 12 transformers will be installed in the plant. There is no provision for storage, recycling or transport of decommissioned photovoltaic panels as electronic hazardous waste. It is not specified how much waste the decommissioned panels and carriers will generate.
A total of 18,129 m3 of land will be removed. It will be stored at the edge of the solar plant area.
It is unacceptable to build a solar plant on such fertile land in the area of 128.3 ha and lose the fertile land that is so necessary for agriculture. The economic damage of losing that fertile land has not been estimated, and how much the damage caused will outweigh the economic benefit of building a solar plant in that area.
In the EIA report, the impact of the electric and magnetic field on the public and employees during the operation of the "Masrik-1" solar plant was assessed as long-term and indirect. It is not specified what effect this field can have on human health.
The positive expert assessment conclusion BP 000061 issued by RA Environment Ministry dated on 17.07.2019, there is no expert assessment requirement regarding the settlement of these problems.
Considering these problems and the fact that the term of positive expert assessment conclusion BP 000061 for the construction of the "Masrik-1" solar plant has expired, we propose to revoke positive expert assessment conclusion BP 000061. The construction project of "Masrik-1" solar plant must undergo a new examination, where all risks will be considered and appropriate solutions will be provided."
September 12, 2022 at 11:44