Response by RA Environment Ministry to EcoLur's Proposals on Construction of "Masrik 1" Photovoltaic Power Station

Response by RA Environment Ministry to EcoLur's Proposals on Construction of "Masrik 1" Photovoltaic Power Station

"EcoLur" Informational NGO carried out monitoring of "Masrik 1" solar photovoltaic plant construction project. EcoLur has dispatched a letter to RA Environment Minister Hakob Simidyan, International Finance Corporation Armenia Senior Investment Officer Arman Barkhudaryan, Head of Yerevan Resident Office of the European Bank for Reconstruction and Development George Akhalkatsi, General Director of "FRV Masrik" CJSC Tristán Higuero and Authorized Representative of "FRV Masrik" CJSC Deniz Saidov submitting the findings of the monitoring on the construction of “Masrik 1” solar photovoltaic station construction project and its proposals in this regard.

In particular, considering the requirement of Article 20 (7) of RA Law "On Environmental Impact Assessment and Expertise", Environment Ministry was proposed to revoke the positive conclusion of the environmental impact assessment report BP 000061 of "Masrik 1" solar photovoltaic plant construction project and appoint new expertise, as RA Ministry of Environment issued the positive conclusion of the environmental impact assessment BP 000061 to "Masrik 1" solar photovoltaic plant construction project on 17.07.2019, but because of the COVID-19 pandemic and the 44-day war, construction of the station was not completed until 2022.

In this case, the requirement of Article 20 (7) of RA Law "Environmental Impact Assessment and Expertise" did not taken into consideration, 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 was proposed to take the following into consideration in the course of new expert assessment: the problem of e-waste management, the problem of erosion of fertile soil, to assess the socio-economic benefits and harms of the implemented project, and to provide socio-economic support to the affected population.

The next proposal was to publish an optimized list of Emerald network candidate areas to exclude the location of the Masrik 1 station construction site in that area. The matter is that the Bureau of the Berne Convention, in its decision adopted at the meeting held in April 2022, once again expressed its concern regarding the significant reduction of the Emerald Network areas planned in Armenia and again urged the authorities to clarify when the revised list will be ready and submitted to the Secretariat.

In its response N 3/07.4/1897 dated 17.02.2023, the letter of RA Environment Ministry says, “In response to your letter dated on 24 January 2023 in regard to revoke the positive conclusion of the environmental impact assessment report BP 000061 of "Masrik 1" solar photovoltaic plant construction project and appoint new expertise, we would like to inform that according to the requirement of Article 20 (7) of RA Law "On Environmental Impact Assessment and Expertise", expert opinion loses its validity if the implementation of the planned activity does not start within one year after the expert opinion is issued. In this regard, Environment Ministry, within its powers, does not have information about whether the implementation of the planned activities for the construction of the station has started within one year after the issuance of the expert assessment or not.

Regarding the other recommendations presented in the letter, I inform you that according to Article 26 of the same law, in order to ensure public awareness and participation, the evaluation and examination processes are subject to public notice and discussion, and the decision of RA Government No. 1325 dated on November 19, 2014, lays down public notice and the order of discussions".

February 20, 2023 at 15:06