The members of "Water Sector" working group of the Public Council under RA Environment Minister sent a letter to the acting Minister of Environment Romanos Petrosyan (the copies are addressed to the NA Speaker Ararat Mirzoyan, and Chairman of NA Standing Committee on Territorial Administration, Local Self-Government, Agriculture Vahe Ghalumyan).
The letter says:
"RA Environment Ministry has proposed a draft law" On Making Amendments to RA Water Code", which proposes: Eliminate one of the grounds for rejection of water use permit applications under Article 30.1, Part 2, Clause 2 (b) of RA Water Code, if "2) the construction of small hydroelectric power plants is carried out in specially protected areas."
The members of "Water Sector" working group of the Public Council under RA Environment Minister, discussing the proposal of the mentioned legislative amendment, is against the amendment to RA Water Code, with the following reasons:
In case of adoption of the proposed amendment to RA Water Code, the construction of small hydropower plants in the buffer zone of SPANs may endanger the stability of the whole ecosystem, protection of flora and fauna, as the construction of small hydropower plants will disrupt the local landscape, in case of laying pipelines, deforestation and activation of landslides are possible. If the river water is piped, the hydrological regime of the river and the local climate will change, which, in their turn, will have a negative impact on the flora and fauna of the area.
The Republic of Armenia has stated that it is pursuing the EU Green Deal, which achieves the goals of sustainable development, as it has ratified the European Wildlife Conservation Convention, and the European Landscape Conventions, where their requirements cover not only SPANs, but also their buffer zones, small hydropower plants with a capacity of less than 1 MW do not undergo environmental expertise, so SPAN buffer zone biodiversity, landscape and the general ecosystem is left without an EIA assessment, which is necessary for the protection of SPANs, including the buffer zone.
Following the amendment of Article 30.1 (2(2(b))) of the Code, the fish in the rivers is jeopardized, which does not have a SPAN and a buffer zone.
The proposed project obviously does not consider the trend of declining water resources in Armenia as a result of climate change, and if the project is adopted, the dynamics will accelerate even more.
Based on the above-mentioned substantiations, the working group of the Public Council under RA Environment Minister proposes not to submit the draft law "On Making Amendments to RA Water Code" to the discussion of the RA National Assembly, add an amendment to Article 30.1 of the Water Code and refuse to provide WP for the construction of SHPPs not only in the buffer zones of specially protected areas, but also in specially protected areas.
The letter has been signed by:
“National Water Cooperation” NGO
“EcoGarbage” Environmental NGO
“EcoLur” Environmental NGO
“Forests of Armenia” NGO
“Econews.am” Environmental News Website
June 14, 2021 at 15:44