

EcoLur
EcoLur has applied to Nature Protection Ministry demanding to reject “Arpa 3” SHPP project submitted by “Jinj Arpa” LLC for the environmental expertise. Nature Protection Minister Aram Harutyunyan and Nature Protection Ministry “Environmental Expertise” SNCO director Andranik Gevorgyan were filed an application, which says, “The impact of “Arpa 3” SHPP on “Jermuk Forest” and “Jermuk” forest reserves, landscape and biodiversity hasn’t been assessed at all. Below are the substantiations:
- «“Arpa 3” SHPP poses great hazard to the mineral waters of Jermuk. “Arpa 3” SHPP will be constructed in the territory of “Jermuk” state hydrological reserve. As the project says, “...for the purpose of preserving the basins supplying mineral waters the project plans to use explosions with small capacity to reduce the impact of the works to minimum.” The mine of Jermuk mineral waters is known to be very sensitive to explosions, as Ruben Yadoyan, PhD in Geological sciences, warned many times. Mineral waters can be damaged due to uncontrollable explosions and waters won’t flow there any more. The assessment of this risk isn’t mentioned in the project at all.
- The impact on biodiversity mentioned in “Arpa 3” SHPP doesn’t comply with the reality and the data laid down in the project contradict to each other. The project speaks about the river biodiversity. “The studied area has only one endemic plant species from Dipsacaceae − Cephalaria armeniaca.” But then the same project speaks about the absence of endemic species. Under the project, the data on biodiversity are taken from the books by S. Dali published in 1954 and A. Magaqyan published in 1941, but these data can undergo changes during the time. How these data were compared with the Red Books of 1987 and 1989, when the new Red Book of Armenia was published in 2010.
- On 14 November at the public hearings of “Arpa 3” SHPP project held at Jermuk Municipality “Jinj Arpa” Company CEO Spartak Avagyan said that they concluded an agreement with “ArmForest” SNCO of Agriculture Ministry of Armenia, which lays down compensation for cut down trees and bushes. But the project itself doesn’t say anything about the number of trees and bushes to be cut down and what the amount of the damage will account for. It’s not excluded that these bushes and trees are in the control of “Jermuk Forest” reserve under the supervision of “ArmForest” SNCO.
- The borders of specially protected areas exposed by the project are not mentioned on the project map. It can be supposed that the impact may have irreversible consequences on the ecosystem of Arpa River in the range of 2.8 km, as this section will be taken into pipes. Under the project, the environmental flow makes up 0.42m3/sec. For our part we would like to mention that Nature Protection Minsitry also bears responsibility for the “Jermuk Forest” and “Jermuk” hydrological reserves controlled by “ArmForest” SNCO.
- The project doesn’t mention the assessment of landslide risks. Taking into consideration the case of “Khachaghbyur-2” SHPP in Getahovit, when 30-ton rock fell off on the excavator and killed 27-year-old driver, as well as in compliance with the European Landscape Convention, an expert opinion about the landslides is needed, as well as an opinion about high seismicity, as Vayots Dzor Region is characteristic of seismicity of 8-9 points.
- The procedure of holding public hearings of “Arpa-3” SHPP hasn’t been complied with either. The residents haven’t been informed about the hearings. Vayots Dzor Region doesn’t have its won mass media, while no information was displayed in Jermuk Municipality, where the public hearings were held. No minutes were drawn up during the hearings and so far it’s hasn’t been presented to the participants of the public hearings.
We would like to ask to provide us the copy of the minutes, when it’s submitted to the Ministry. Taking into account the aforementioned facts, the project as such doesn’t meet the requirements of RA Law on “Environmental Impact Expert Assessment” and should be rejected by “Environmental Expertise” SNCO of Nature Protection Ministry of Armenia.
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December 13, 2013 at 17:32
