Suggestions on the issues brought up by the Small Hydropower Plants
We all are well aware that from the ecological perspective the SHPPs are considered much cleaner sources of electricity production than thermal power plant and nuclear power plants. However, in Armenia due to the incorrect strategy chosen by the RA Government for development of this sector and pursued short-sighted policy, as well as massive construction of the SHPPs and uncontrolled exploitation, have brought forth many ecological and social problems, and among different groups of society have emerged conflicts of interest.
All this is a direct consequence of imperfections and contradictions of the laws and other legal acts, as well as in the implementation of ratified international legal acts by the RA, ie, their localization and expression through our legislation, corruption and nepotism practices in the structure of public administration, lobbying in different levels of this sector, as well as the low level of eco-consciousness and eco-awareness of the public.
The above mentioned is motivated by the following arguments.
1. Currently the ecosystem approach is absolutely missing at the water use permits granted for the construction of the SHPPs, which is a direct consequence of the RA Government Decision h.927-N “On the demand for water for drinking- household and agricultural purposes in accordance with the RA water basin areas as well as establishing environmental flows assessments” dated 30.06.2011, according to which for determining the cost of minimum output of the environmental flows as a basis is considered the average discharge of 10 consecutive days in seasonal period of the year. This means that if the average discharges of those 10-days are for example 5 liters /sec, during the long-term hydrological monitoring of one of the scarcest in water year then we can define it as an environmental flow for the entire year and actually to desiccate the river. This decision has nothing at all to comply with the needs of the conservation of ecosystems and cannot provide the vital activity of those natural ecosystems.
In this connection we are offering:
• To review the above mentioned RA Government Decision, and on the basis of the evaluation of environmental flow and calculation method really to set the river basins hydrological, hydro-morphological, hydro-geographical, hydro-chemical and hydro-physical, environmental, seasonal and other features, accepting as an undeniable fact that the river is a natural element providing long-term ecosystem service, and not just a physical mass of flowing water.
• After the adoption of the environmental flow calculation new method, to review all previously issued water use permits.
2. There is a lack of comprehensive and scientifically based evaluation methodology in Armenia on the SHPPs impact upon the ecosystem, as well as socio-economic, demographic, cultural and other influences. Instead, by the RA legislative and executive authorities have been adopted such laws and decisions that enable enterprises to build small hydropower plants on the rivers, making it a lucrative business. To it also contributes the high price of electricity for the SHPPs built on the river (21AMD for per kilowatt / hour).
In connection with this we suggest:
• Suspend the all SHPPs construction and granting new licenses until developing comprehensive and scientifically based methodologies on variety of impacts arising during those construction and operation by the RA Government
• After developing methodology should be reviewed admissibility of already existing (operating) all SHPPs on the basis of the developed complex criteria.
• The RA Public Services Regulatory Commission should calculate, justify and set a realistic price which after returning the investments would be gradually reduced, owing to which the saved funds should be allocated to other sources of clean electricity generation development. The demand for alternative energy sources should be our priority in the coming years.
3. The Environmental expertise generally does not serve to its purpose, and there is absolutely no control over the SHPPs construction, and operation. In many cases as a result of absolute lack of control are not even maintained currently acting minimum requirements and the rivers are desiccated periodically. About these things are witness and speak out only the residents, environmentalists and journalists of the affected community(s).
In connection with this we suggest:
• To conduct audits, including monitoring in the Environmental Expertise NGO, in what capacity are being considered the SHPPs construction projects, and on what basis and professional analysis are being widely provided positive conclusions.
• In this regard is very dangerous and unacceptable for us transferring the SHPPs from the “B” category to “C” category in the RA new draft law on “Environmental impact assessment and expertise” by unexplained reasons, which allows giving conclusions in a simplified procedure and without any serious evaluation.
• It should be thoroughly examined the water use permits provided for SHPPs constructions by the Water Resources Management Agency of the RA.
• All existing small hydropower plants must be equipped with automatic systems controlling environmental flows quantity, which must be connected to a single computer network that will allow any time to see and record the volume of water left in the river. This information should be available online for any citizen.
4. Public hearings in the affected communities are simply a formality: the negative opinion(s) expressed by the community, environmentalists and civil society usually does not play any role, which leads to various disputes and problems between the projectors, local government officials, community residents, environmentalists and civil society (eg Trchkan waterfall, Khachaghbyur -1 and Khachaghbyur 2 small hydro power plants – Getahovit, Stepanavan, Martz, Byurakan, Shatin, Argichi and many other cases).
In this regard we suggest:
• To accept relevant legal acts, by which will be fixed a provision that water use permits for any SHPP construction and environmental positive findings will be given to a developer, only in accordance with the positive reviews of the affected community, environmental experts and civil society. If the community is against it, then the state authorized body should provide a negative conclusion to the developer.
• It should be definitely banned the SHPPs construction in the specially protected nature areas and on the rivers, which are considered settlement for plants and animals listed in the red-book of the RA.
5. The idea of a reasonable use of natural resources is ignored, and the river is seen only as a potential for hydropower resources. The cumulative impact of SHPPs on the environment and affected communities is practically ignored, when several small hydropower plants are built on one river.
In this regard we suggest:
• Immediately start monitoring works in this direction and give some professional arguments and conclusions, if it’s permitted to take up the all river into the pipe or to build several SHPPs on one river. Finally, it should be understood and evaluate what kind of adverse ecological effects may be brought more than 300 small hydropower plants construction and operation in a small country like Armenia. In our opinion this is one of the most important issues, which concern not only the civil society, but also the environmental experts.
We understand that these issues can be resolved only by political will of the government system, which, unfortunately, is missing today.
Translated by Anush Beybutyan