SEVAN COMMITTEE’ REFUSAL TO ANSWER ENQUIRY ON AMULSAR PROJECT IS VIOLATION OF ARMENIAN LEGISLATION
13:44 February 06, 2015
The Scientific-Expert Committee on Lake Sevan Preservation refused
to provide EcoLur the text of the positive opinion on Amulsar project
issued in 2014. The substantiation of this refusal doesn’t comply with
the essence of the enquiry and violates the Armenian legislation. On
16 October 2014 EcoLur made an enquiry to the Committee asking provide
the text of the opinion on Amulsar project issued in 2014.
In reply, Committee member Yuri Javadyan says in his letter dated
on 19 January 2015, “The Scientific-Expert Committee on Lake Sevan
Preservation by NAS RA informs that the committee examined “Amulsar
gold-bearing quartzite mine in Vayots Dzor Region, Armenia” project
on 24.09.2014 and laid down proposals consisting of two clauses in
its minutes no. d7/14.
The Nature Protection Ministry organized public hearings of the project
EIA in Gorayq Rural Municipality, Syunik Region, on 27.09.2014, where
“Geoteam” CJSC recorded that tis had made relevant amendments and
supplements to the project based on the proposal made by the Committee.
Your absence in the hearings of the project as assessed as a confirming
approach to the project solutions, so your letter dated on 16.10.2014
was not replied to.
In its minutes, you can receive information about the project from
the Environmental Expertise SNCO of Nature Protection Ministry,
where all the project documents are available.”
Yuri Javadyan replied to EcoLur’s enquiry after several months, thus
violating Article 9 (7(1)) of RA Law “On Freedom of Information”,
which says, “The answer to written inquiry is given in the following
deadlines: a) If the information required by the written inquiry is not
publicized, than the copy of that information is given to the applicant
within 5 days after the application is filed.” Article 8(2(1)) of the
same law is also violated, ” Information request cannot be declined, if
it presents the overall economic situation of the Republic of Armenia,
as well as the real situation in the spheres of nature and environment
protection, health, education, agriculture, trade and culture.”
Javadyan’s refusal also violated Article 4 of the Aarhus Convention
ratified by Armenia.
The letter substantiation of the refusal “Your absence in the hearings
of the project as assessed as a confirming approach to the project
solutions, so your letter dated on 16.10.2014 was not replied to.”
doesn’t comply with reality and provisions prescribed by “On Public
Noticing and Discussion”, Article 29 hereof says, “Public opinion
is considered to be positive, if none of them attends the public
discussions or submits its observations or proposals.”
It should be mentioned that EcoLur’s team took part in the public
discussions on Amulsar project held in Gndevaz Village, Vayots
Dzor Region, on 25.08.2014 and submitted its negative opinion to
“Environmental Expertise” SNCO of Nature Protection Ministry, which
“Environmental Expertise” SNCO Deputy Director Henrik Grigoryan read
at the public hearings held in Gorayq on 27.09.2014.
This procedure completely complies with the requirements of Article
29 of “On Public Noticing and Discussion”.
As it’s known, in 2012 the Scientific-Expert Committee on Lake Sevan
Preservation issued a negative opinion to Amulsar project and provided
the text of its opinion to EcoLur without any obstacles. At that
time the Chairman of the Committee was the late Vladimir Movsisyan,
who said in his interview with EcoLur, “Amulsar won’t be implemented
unless I’m alive.”