96 ARMENIAN NGOs CONDEMN POLICY OF AUTHORITIES REGARDING ENVIRONMENT

Noyan Tapan

Se p 17, 2008

YEREVAN, SEPTEMBER 17, NOYAN TAPAN. 96 Armenian NGOs, on September 13,
made a joint statement expressing concern with the decisions regarding
the environment.

The statement read:

"We, the undersigned civil society representatives of the Republic
of Armenia (RA) express our deep concern and indignation regarding
the de-national nature of recent developments and illegal processes
related to the environment in Armenia, in particular the decision
on increasing water release from Lake Sevan up to the mark of 360
million cubic meters (which is twice as much as it was in previous
years), adopted by the RA National Assembly on August 14 2008 upon
the initiative of the RA Government.

We remind that Lake Sevan is the strategic freshwater reservoir of
the Republic of Armenia as well as the region, and the actual use of
the lake shall pursue the aim of restoration and preservation of this
source of drinking water, taking into consideration drinking water
scarcity in the whole world. Impeding the increase of the level of
Lake Sevan for any purpose may be hazardous for the lake ecosystem.

We are convinced that the increase of water release from Lake Sevan
and the consequent decrease of the lake’s level are in the interest
of a group of individuals. The decision adopted in August 2008 is
a precedent to raise t he same issue in the following years and to
impede the rise of lake’s level on various pretexts. The slow-down of
the cleanup of the lake shores, delays in operation of Vorotan-Arpa
tunnel, holdup of reconstruction of highways, speculation of emergency
weather conditions, proposals on introducing amendments to the RA Law
"On Lake Sevan", and others serve the mentioned aim.

We are skeptical about the "expert conclusion" drawn by the Expert
Commission on Lake Sevan and we cast doubts on the independence and
incorruptibility of "experts" who concurred with the release of water,
which would bring down the lake’s level and lead to its negative
water balance.

We record that the enrollment of representatives of society into
various councils and commissions founded by different institutions in
RA, is, in fact, an imitation of democracy and transparency. The fatal
for the most important strategic resource in the country decision has
not been presented and discussed even in structures like the National
Sustainable Development Council, which operates adjunct to the RA Prime
Minister, founded with the aim of ensuring sustainable development of
the country and balancing economic, social and environmental issues,
or the Board of Experts of the Aarhus Center founded by the joint
initiative of RA Ministry of Nature Protection and OSCE Office in
Yerevan, aimed at fostering public participation in decision-making
on environmental matters.

=0 AWe state that the decision on doubling the water intake from
Lake Sevan has been adopted by the RA Government and the RA National
Assembly without a comprehensive study and scientific justification
for the demand of water, without assessing possible damages to the
environment as a result of such a measure as well as without adequate
notification and engagement of stakeholders, including residents of
coastal communities. This decision violates RA Constitution Article
10, RA Water Code Article 5, RA Law on Lake Sevan Article 11, RA
Law on Environmental Impact Assessment Article 15 and UN Economic
Commission for Europe Aarhus Convention on Access to Information,
Public Participation in Decision-Making and Access to Justice in
Environmental Matters Articles 4, 7, 8.

We condemn the environment-related policies run by RA authorities and
believe that they do not comply with their obligations prescribed by
the RA Constitution on ensuring environmental protection, recovery
as well as rational use of natural resources.

We demand

to immediately restore in the RA Law on "Approval of Annual and
Complex Measures on Conservation, Restoration, Reproduction, and Use
of the Ecosystem of Lake Sevan" the maximal 170 million cubic meters
water intake threshold, which has been established based on perennial
research of scientific-research institutes rather than suspicious
reasons given by a couple of institutions;

to reveal and publicize the causes of20water scarcity in Ararat Valley
and the ways how the water of Azat and Aparan reservoirs has been
spent in 2008, to undertake immediate actions on demolishing illegal
constructions on the lakeside, organizing thorough cleanup of the
shores and preparing those for the rise of the level of the lake;

to reveal the violations of RA legislation and to call to account
those guilty, in particular the officials and others involved in
corrupt transactions.

We inform that for us, the undersigned organizations, which represent
the active stratum of the civil society, it would be possible to
collaborate on environmental issues with relevant state bodies of
the Republic of Armenia if:

we do receive an appropriate response to our aforementioned demands;

we get convinced that in environment-related decision-making the RA
Government demonstrates political will and acts in compliance with
the RA legislation and international commitments;

we become confident that state bodies, indeed, take proper account of
the NGOs’ opinions and comments rather than making their participation
a futile imitation."

96 civil society organizations have signed the statement.