Public Assessments on Expediency of Nubarashen Household Landfill Site Management Project (To Be Continued)

Public Assessments on Expediency of Nubarashen Household Landfill Site Management Project (To Be Continued)


EcoLur continues its series of publications on the discussions of expediency of Nubarashen solid waste management loan. The European Bank for Reconstruction and Development (EBRD) and the European Investment Bank has provided loans of 8 million Euros each (a total of 16 million Euros) and another 8 million Euros has been provided by the EU NIF Fund.
This publication will speak about 'ARMENIA: YEREVAN SOLID WASTE PROJECT – ENVIRONMENTAL AND SOCIAL DUE DILIGENCE “ESDD7” NON-TECHNICAL SUMMARY'. This document has been developed with the order of Yerevan Municipality by two Austrian companies - BERNARD Ingenieure ZT GmbH and HYDRO INGENIEURE Umwelttechnik GmbH.
The main question that arises while reading this document is the compliance and expediency of the Social and Environmental Policy of the EBRD approved by its Board of Directors on 7 May 2014.

The document makes references to the requirement of 2014/52/EU Directive on environmental impact assessment, as well as 1999/31/EU Directive, which is on the landfill of wastes.
It should be mentioned that 1999/31/EU Directive divides landfills into three classes based on their extent of toxicity, type, characteristics etc: landfills for hazardous waste; landfills for non-hazardous waste; landfills for inert waste. Different requirements are posed to landfills, which collect these wastes. Moreover, the need for waste monitoring and supervision is mentioned many times.

The EIA of Yerevan solid waste management project speaks about household wastes not specifying their type. It's clear there are no studies in this regard on exactly what is dumped into Nubarashen landfill, that's why the clause of the project, which speaks about monitoring and supervision, misses the description of real risks inherent to a certain type of waste, it just cites the clause of the Directive.

It should be mentioned that garbage sorting is not carried out in Yerevan. The project also doesn't plan to have any sorting. Nevertheless, individual examinations and studies carried out in different period of times show that several thousands of enterprises operate in Yerevan, including small and non-registered enterprises, for example, mirror production, car wash and repair, construction companies, medical establishments, barber's shops and dental clinics.
They can produce toxic wastes, infected syringes, biowastes, strong acids, alkali etc. All these enterprises get rid of the wastes generated due to their operation in a non-regulated manner. The project doesn't assess their share in solid household wastes.

The main part of the wastes is plastic – sometimes up to 50%. Negotiations have already been running for several years about possible investments on the construction of a recycling plant. Financial, economic, environmental and social impacts are assessed for potential investors.

The technical feasibility study of the project outlined that waste sorting and recycling is beyond the project, therefore, the loan project is in direct conflict with the potential investors of a recycling plant.

The project has a 'green' component - CO2 reduction in the atmosphere at the expense of methane burning. It's noteworthy that estimates are made for the new section not taking into consideration the fact that the new section is the natural continuation of the operating landfill, whereas since 2009 methane has been burnt in torches for the reduction of certified emissions of carbon (see the previous material on Shimizu company). This means that the figures on the reduction of CO2 laid down in the project need specification.

The project has data that forest areas will be used. Out of 17.91 ha of forest-planted area 2.7 ha is real forest, the rest doesn't have a forest on it. It says that the municipality is running negotiations with 'ArmForest' for damages in the form of a new forest area. That is, the project takes forest area of the landfill, on which funds have been spent for forest plantation, even though these funds have been spent unsuccessfully. Forest fund suffers here, which has both forest-covered and forest-free areas. The outcomes of the negotiations in this regard are not presented.

EBRD's social policy is expressed in its gender requirements:

• EBRD Strategic Gender Initiative
• EBRD Gender 1 Guidance note
• EBRD Gender Toolkit 1 and 2
• EBRD Environmental and Social Policy, 2008
• RA Law On Equal Rights and Equal Opportunities for Men and Women

It should be mentioned that both men and people and even children work in the landfill without any permit, who earn their living there. Men work as drivers, as a rule, while women and children sort the garbage loaded from the trucks thus dividing income within their families, that is, gender approach is set by the life and is not decided specifically within the given project.

15:24 February 01, 2017

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