Hung Nguyen District has pointed out numerous violations at the high-tech Israeli tilapia farming project of Synot Asean Joint Stock Company.

On September 21, 2022, the Provincial People's Committee issued Official Letter No. 809/VPUB-NN providing guidance.People's Committee of Hung Nguyen DistrictReview and report on the implementation status of the high-tech Israeli tilapia farming project in Hung My commune, Hung Nguyen district, invested by Synot Asean Joint Stock Company. By October 14, 2022, the People's Committee of Hung Nguyen district had submitted Report No. 427/BC-UBND to the Provincial People's Committee, with the following content:

Synot Asean Joint Stock Company received approval from the People's Committee of Nghe An province for the investment in a high-tech Israeli tilapia farming project in Decision No. 2333/QD-UBND dated June 1, 2017, and approval of the detailed construction plan at a scale of 1/500 in Decision No. 5704/QD-UBND dated November 24, 2017, with a total area of ​​64,101 m².², including the following items: Main gate; Secondary gate; 1-story guardhouse, construction area 16.5m².²A one-story factory building with a construction area of ​​450m².²Warehouse and auxiliary buildings, 1 story high, construction area 200m².²; a 3-story office building with a construction area of ​​325m².²; a two-story workers' accommodation building with a construction area of ​​140m².²Sports field, construction area 250m²²; a one-story garage with a construction area of ​​96m².²Parking lot; one-story water treatment plant, construction area 90m².²Water filtration tank, construction area 320m²²; power station, construction area 20m²²The generator house is a one-story building with a construction area of ​​16m².²Sedimentation pit, area 2720m²²Sedimentation pond, area 2540m²²Fish fry rearing pond, area 1165m²; breeding pond, area 1475m².²; breeding pond, area 2,145m²²; fish pond for raising fish for consumption, area 17,715m²²; a one-story garbage collection building with a construction area of ​​16m².²The pump house is a one-story building with a construction area of ​​12m².²Wastewater treatment tank with an area of ​​84m².²; drainage channel with an area of ​​2,705m²The building density is 2.79%, and the building height ranges from 1 to 3 stories.

Report No. 427/BC-UBND dated October 14, 2022, from the People's Committee of Hung Nguyen District. Photo: NPV

The People's Committee of Nghe An province leased land under Decision No. 91/QD-UBND dated December 7, 2018, and issued a certificate of land use rights, ownership of houses and other assets attached to the land, code CN 785495, on May 24, 2019, to Synot Asean Joint Stock Company with a total area of ​​63,997.4m².²(including: aquaculture land 55,238.8m², commercial and service land 8,758.6m²). On July 19, 2019, Synot Asean Joint Stock Company was granted Construction Permit No. 63GP/SXD by the Department of Construction of Nghe An province.

Regarding the project implementation status:

After receiving the land allocation from the Department of Natural Resources and Environment, the investor proceeded with land compensation and clearance (costing nearly 5 billion VND) and paid the deposit.761 million VND, payment for the protection and development of rice-growing land 1.082 million VND, with land lease payments totaling 19.5 million VND for 2019 and 4,448.9 million VND for the entire lease period. The investor (Synot Asean Joint Stock Company) has proceeded with the construction of the project components.

November 116/2In 2020, the People's Committee of Hung Nguyen District issued Decision No. 512/Decision No. 7916/UBND-TD dated November 11th, 2020, of the Provincial People's Committee on the establishment of an inter-agency team to inspect and handle violations at land lease projects in Hung Nguyen district in 2020, including the high-tech Israeli tilapia farming project in Hung My commune, Hung Nguyen district, by Synot Asean Joint Stock Company, was issued to promptly address violations that occurred from the time the investor began construction of the project. However, due to the inspection taking place during a period of complex developments in the Covid-19 pandemic, the Provincial People's Committee requested the Hung Nguyen District People's Committee to halt the inspection according to Official Letter No. 7916/UBND-TD dated November 11th./2020.

An image of a construction project is being promoted on a fan page allegedly belonging to Synot Asean Joint Stock Company. Photo: NPV

To carry out state management work on construction order in the area, on day 17/6/In 2021, the People's Committee of Hung Nguyen District, together with the People's Committee of Hung My Commune, conducted an inspection of the project implementation by Synot Asean Joint Stock Company. At the time of the inspection, the investor had constructed the following items: main gate, guardhouse, and office building (area 325m²).²), parking lot, water plant, water filtration tank, power station, generator house, garbage collection house, pump house, wastewater treatment tank, pond system, land leveling, construction of internal road system (total length 900m), drainage canal, planting of trees and some structures not included in the construction permit including: Old warehouse (75m²), fish feed processing plant (50m²wooden stilt house(70m²), rest shelter (9m²), artificial mountain model foundation 1 on the Northwest side of the project (690m), artificial mountain model2 Southwest side of the project (300m)²), golf practice facility foundation (300m)²), model foundation of the 7 wonders of the world (454m)²An administrative violation report has been filed for the act of constructing buildings without a construction permit. Date25/In June 2021, the Chairman of the People's Committee of Hung Nguyen District issued Decision No. 583/QD-XPVPHC imposing an administrative fine of 30,000,000 VND on Synot Asean Joint Stock Company for the violation of "Organizing construction work without a construction permit when a construction permit is required"rice(Thirty million dong).

August 14th2In 2020, Synot Asean Joint Stock Company submitted an application to the Provincial People's Committee and relevant provincial departments and agencies for consideration regarding the adjustment of the investment policy. After receiving feedback from the Departments of Natural Resources and Environment, Construction, Agriculture and Rural Development, Tourism, the Provincial Tax Department, and the People's Committee of Hung Nguyen District, the Department of Planning and Investment issued Document No.622/On February 25, 2022, the Department of Planning and Investment reported to the People's Committee of Nghe An province on the adjustment of the investment policy for the high-tech Israeli tilapia farming project in Hung My commune, agreeing to submit it to the People's Committee for consideration and issuance of a Decision to adjust some contents of Decision No. 2333/QD-UBND dated June 1, 2017 of the People's Committee of the province. However, after consideration, the People's Committee of the province issued Document No. 1444/UBND-NN dated March 8, 2022, assigning the Department of Planning and Investment to take the lead in coordinating with relevant agencies to review and clarify some contents of the project.

Following the directives of the Provincial People's Committee, on March 11, 2022, the Department of Planning and Investment issued document No. 826/SKHĐT-DN requesting the Departments of Construction, Natural Resources and Environment, Agriculture and Rural Development, and the Tax Department to continue coordinating and providing feedback on the investor's proposed adjustments. After receiving responses from the relevant departments and agencies, and the explanatory document No. 145/GT-SYNOT dated May 25, 2022, and the commitment letter dated June 28, 2022 from Synot Asean Joint Stock Company, on August 25, 2022, the Department of Planning and Investment, in coordination with the Departments of Finance, Construction, Natural Resources and Environment, Agriculture and Rural Development, the Nghe An Provincial Tax Department, the People's Committee of Hung Nguyen District, and the People's Committee of Hung My Commune, conducted a site inspection and prepared an inspection report for the project. On September 7, 2022, the Department of Planning and Investment issued Document No. 3533/SKHĐT requesting the Provincial People's Committee not to consider approving the adjustment of the investment policy for the project as proposed by Synot Asean Joint Stock Company. On September 12, 2022, the Nghe An Provincial People's Committee issued Document No. 6917/UBND-NN, which clearly stated that it had not yet considered approving the adjustment of the investment policy for the high-tech Israeli tilapia farming project in Hung My commune.

During the process of adjusting the investment policy for the project, the investor continued to construct project components without the approval of the Provincial People's Committee, including:

Completed 3 construction items including: Artificial mountain model 1 on the northwest side of the project, with a construction area of ​​690m².²; model of the 7 wonders of the world, construction area 454m²²Golf practice facility, construction area 300m².².

Construction of 7 new structures, including: 4 reinforced concrete pillars 1.5m high, with a construction area of ​​25m².²Reinforced concrete foundation, construction area 344.08m².²The foundation consists of an interior panel with steel reinforcement, and the construction area is 452.45m².²Circular building (reported by the investor as a workers' canteen), construction area 530m²²; a two-story house behind the circular house (according to the investor's report, it's a workers' rest house), with a construction area of ​​102.24m².²; temporary steel frame structure, erection area 1,500m²²Temporary chicken coop, construction area 485m².².

On a fan page allegedly belonging to Synot Asean Joint Stock Company, there is extensive promotion of a new tourist destination, built on land designated for a high-tech Israeli tilapia farming project. Photo: NPV

Regarding compliance with the law in project implementation:

Regarding the legal documentation prior to project implementation, ensuring compliance with the law, the company has received approval from the Provincial People's Committee for the investment policy, the project has been approved with a detailed planning map at a scale of 1/500, the Nghe An Provincial People's Committee has issued a decision on land lease, the Department of Natural Resources and Environment has issued a certificate of land use rights, ownership of houses and other assets attached to the land, the Department of Construction has issued a construction permit, and the investor has fulfilled its financial obligations as required.

The project implementation has received significant attention from the investor: the internal road system is 60% complete, the water supply system is 92% complete, the electricity supply system is 95% complete, the land leveling and fish ponds are 90% complete, and the water treatment plant, water filtration tanks, power station, generator house, garbage collection house, pump house, and wastewater treatment tank have been constructed. The total area of ​​fish ponds, breeding ponds, sedimentation ponds, and supply sedimentation ponds is 34,900 m².²(including 9,500 m outside the project area)²The project essentially ensures the main objective and function of the project, which is to commercially raise Israeli tilapia using high technology. The project contributes to the transformation of the agricultural sector's structure, while simultaneously converting inefficient single-crop rice production land and swampy land into high-tech agricultural land, contributing to socio-economic development in the area and creating jobs for people.ricelocal people.

During the project implementation process, the investor proactively prepared the necessary documents to request adjustments to the investment project's policy, submitting them to the competent authorities for consideration and decision.

The company's violations during the project implementation:

Upon inspecting the actual construction status of the project components and comparing it with the approved plan, Synot Asean Joint Stock Company has committed the following violations during the project implementation:

Regarding construction regulations:

Construction was carried out in a manner inconsistent with the content of the issued construction permit, including 5 construction items: land leveling, fish pond excavation, and road construction.riceInternal transportation, canal systems, and construction of office buildings.

Six construction items were built without a building permit, including: a miniature artificial mountain model on the northwest side of the project, with a construction area of ​​690m².²(on commercial service land and internal traffic land); Artificial hill model on the southwest side of the project, construction area 300m².²(on commercial service land and internal transportation land); Model7 A world wonder, with a built-up area of ​​454m².²(on commercial service land); Wooden stilt house, construction area70m²(on commercial service land and internal traffic land); Resting gazebo, construction area 9m²²(on commercial service land); Golf practice facility, construction area 300m².²(on land used for aquaculture and internal transportation).

These items were constructed by the investor before the time of submitting the application for adjustment of investment policy (month).8/In 2020, the investor was fined for administrative violations by the District People's Committee, but continued construction without completing the necessary adjustments to the construction permit.rice.

Construction of two new structures on land belonging to a project for which a land use right certificate has been issued, in violation of the approved construction plan, includes: a reinforced concrete underground foundation behind the office building, with a construction area of ​​344.08m².²(on commercial service land); 4 reinforced concrete pillars near the main gate, construction area 25m².²(on land designated for commercial services and internal transportation).

Land violations:

The investor has implemented the project on an area of ​​approximately 82,400 square meters.², greater than 18,102m²compared to the area stated in the land use right certificate. The additional area outside the project was leased or borrowed from households by the investor; Construction of 6 project items located outside or partially outside the boundaries of the land use right certificate, including: Circular house, construction area 530m².²(According to the investor's report, it is a workers' canteen); A two-story building behind the circular building, with a construction area of ​​102.24m².²(according to the investor's report, it is a workers' rest house); Old warehouse, construction area75m²Fish feed processing plant, construction area 50m²²Temporary steel frame structure, construction area 1500m².²Temporary chicken coop, construction area 485m²; Construction of a foundation with interior slabs and steel reinforcement behind the golf practice facility, construction area 452.45m².²Using land designated for aquaculture is not in accordance with the provisions of the Land Law.

People's Committee of Hung Nguyen DistrictRecommendation:

After inspecting and reviewing the violations, the District People's Committee directed the Hung My Commune People's Committee to prepare a record of administrative violations and submit it to the competent authority for the issuance of a decision on administrative penalties. Due to the nature of the project, which involves a mix of commercial and service land and aquaculture land, the Hung Nguyen District People's Committee respectfully submits the following to the Provincial People's Committee and relevant departments and agencies for consideration and guidance on handling the matter:

The fanpage, allegedly belonging to Senot Asean Joint Stock Company, promotes images of tourists. Photo: NPV

Regarding construction projects on commercial and service land: According to the investor's report, the following items are included: Artificial mountain model 1 on the northwest side of the project, Artificial mountain model2 Southwest side of the project, Rest pavilion, Wooden stilt house, Model7 The world wonder consists of stylized warehouses, factories, and landscaped structures. Although constructed in violation of the approved plan, the building density and height do not exceed the general regulations of the law on construction planning. Therefore, the District People's Committee respectfully requests the Provincial People's Committee to assign relevant departments and agencies to coordinate with the District People's Committee and the Hung My Commune People's Committee to re-examine and reassess the planning parameters, structure, and function... to determine if they alter the main objective and function of the project, which is high-tech commercial tilapia farming. If the structures do not change the main objective of the project, then adjustments to the construction plan are permitted; if the structures affect the main objective of the project, then they should be dismantled.

Regarding the pond system, internal transportation system, and canal system, some parts were constructed in violation of the plan: After on-site inspection, the District People's Committee found that the technical infrastructure system still ensures the main objectives and functions of the project. The District People's Committee requests the Provincial People's Committee to assign relevant departments and agencies to coordinate with the District People's Committee and the Hung My Commune People's Committee to re-examine and re-evaluate the planning parameters, structure, and functions of these project components to consider adjusting the plan.

Regarding construction projects on aquaculture land, or land located outside or partially outside the project boundary, including: a circular building (reported by the investor as a workers' canteen), a two-story building behind the circular building (reported by the investor as a workers' rest house), an old warehouse, a fish feed processing facility, a temporary steel frame structure, temporary chicken coops, a golf practice facility, and a foundation with a reinforced concrete slab inside behind the golf practice facility. These cases violate the Land Law; therefore, the District People's Committee requests the Provincial People's Committee to assign relevant departments and agencies to coordinate with the District People's Committee and the Hung My Commune People's Committee to handle the violations in accordance with the Land Law.