Decision N 1122-A "On Setting up an Interdepartmental Commission" was adopted by RA Prime Minister on November 25, 2011. The decision was made to draw up an action plan for implementations of obligations Armenia assumed under Aarhus Convention and for coordinating actions to comply with those obligations.

On February 14, 2012 the Ministry of Nature Protection hosted the first meeting of the interdepartmental commission on coordinating actions of Armenia's compliance with its obligations under the Aarhus Convention.

The Press Service of the Ministry of Nature Protection disseminated a Press Release on February 14, 2012 allegedly reporting that "in order to implement that decision the National Assembly of Armenia passed a draft law on Amendments and Additions to the Law on Environmental Impact Assessment in February 2012, and public hearings, as well as parliamentary hearings were held to that end."

In this regard we consider it necessary to state that the reported information does not correspond to reality. Whereas actually pursuant to Article 27.1 of RA Law on Legal Acts the above mentioned draft law did not undergo public hearings and it was presented to the discussion of the National Assembly and passed by illegal procedure.

The interested public opposed the adoption of this law in a grounded way both in November-December 2011 and these days. On the same day, February 14, a number of NGOs and individuals applied RA President demanding that the law be recommitted to NA to be newly examined.
Apart from the fact that the mentioned law was adopted by illegal procedure, the provisions of the law do not meet the requirements of the Aarhus Convention Compliance Committee which is specified in the demand addressed to the President.

During the commission meeting by presenting the national action plan on compliance with the requirements of Aarhus Committee, Deputy Minister Simon Papyan noted that an interdepartmental commission comprising public organizations was set up to meet that requirement.

It should be mentioned that setting up a committee by itself cannot be viewed as an action to meet the requirement of the Aarhus Committee. According to the decision of the Committee the Government of Armenia should take up real measures by April 1, 2012 to meet the demands made; however the Committee launched its work only on February 14.
This confirms that the respective authorities are not truly committed to implement the Committee requirements but only give an imitation of accomplishing work in order to once more gain time.

The non constructive approach manifested by National Coordinator of the Aarhus Committee Aida Iskoyan and Minister of Nature Protection Aram Harutyunyan on Armenia's not violating the Aarhus Convention witness of the above mentioned.

Despite that claim it should the final Conclusions and Recommendations
of the Report of the Compliance Committee reads: "While acknowledging the continuous efforts of the Party concerned in implementing decision III6/b, the Committee finds that there are still shortcomings in Armenian law and practice and, due to these shortcomings in the present case, the Party concerned failed to comply with article 3, paragraph 1, of the Convention (para. 56); and article 6, paragraphs 2, 4 and 9, of the Convention (paras. 70, 77 and 79, respectively).

We hope that the Minister of Nature Protection and the employees will henceforth manifest constructive approach and the commission activity will be directed to taking up real and effective measures to comply with Armenia's international obligations within short time.

Otherwise the activity of the commission seems meaningless and our participation will only legitimize the non adequate actions of the Ministry of Nature Protection. Based on the working mood of the commission and motivations we will make a decision on the issue of our participation in the commission work.

Sona Ayvazyan, Chair of Transparency International Anti-corruption Center
Artur Grigoryan, Lawyer of Ecoera NGO