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DEVELOPMENT OF ALLEGATIONS
Incompatibility with Directive 2011/92 project evaluation
As revealed in the process of environmental impact assessment, the program probes that are now to authorize and EIS suffer from innumerable deficiencies in its justification, documentation, scope and level of detail in the description project alternatives, description of the environment, potential impacts, mitigation measures, and so on. As for the realization of these deficiencies, we refer to the discussion in the briefs that have been filed in that proceeding.
In addition to these shortcomings, there has been a flagrant breach of the right to public and institutional participation in the process of environmental impact assessment, to make available to interested persons and authorities involved documentation provided by the operator without giving a deadline for submitting observations. Such failure occurred through the office of May 20, 2014 submitted by the Director General of Energy Policy and Mines to those interested and affected administrations.
This access to new, complex, profuse and diffuse documentation without granting a deadline for comments is a breach of Article 6 of Directive 2011/92, Article 6 of the Aarhus Convention 1998 and Article 9 of the Real Legislative Decree 1/2008.
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