“Amberd 1” and “Amberd 2” SHPP Monitoring Results (Photos)

“Amberd 1” and “Amberd 2” SHPP Monitoring Results (Photos)

EcoLur

In the framework of the project entitled “Support to the Reforms of SHPPs through a Dialogue between the Public and The Ministry of Nature Protection of the RA for the Purpose of River Ecosystem Use” the expert group visited Aragatsotn Rgion for “Amberd 1” and “Amberd 2” SHPPs. The SHPPs are constructed on the Ampur River (length – 36 km). “Amberd 1” SHPP is located in the administrative area of Orgov community, while “Amberd 2” SHPP is located in the administrative area of Orgov and Byurakan communities. The SHPPs are operated by “Amberd HPP” LLC.

“Amberd HPP” LLC owner didn’t allow the expert group to enter the SHPP area. The road running to SHPPs and Ampur River was blocked with a turnpike and it was substantiated that the road was constructed by the SHPPs.  That’s why we submit only official data taken from the package of permitting documents and certain observations from the visits.

  • The static pressure of the SHPP isn’t mentioned in the project. According to the project, estimated pressure –117.1m,  the estimated yield used by the SHPP is 2.4 m3/s, projected capacity – 2.28 MW, according to the certificate issued by the Public Services Regulatory Committee, capacity – 3350 kW. According to the certificate issued by the Public Services Regulatory Committee, the factual useful delivery of the electricity is  5.2     million kWh, according to the project, the estimated production is 5.69 million kWh, duration of license - 10.02.2010- 10.02.2025, water usage permit - 03.11.2010- 03.11.2013.
  • The fish passway of “Amberd 1” SHPP is completely sufficient for the brown trout and to some extent for the Barbus dok in the depicted water regime.
  • Fish-protecting structure is missing.
  • You can find brown trout in the Ampur River - Salmo fario. The availability of Kura barbell,  Barbus cyri, and the South Caspian sprilin, Alburnoides eichwaldii, is also possible.
  • The environmental flow of “Amberd 1” is laid down 0.11 cum/s in the water usage permit, while SHPP construction project says 0.06 cum/s.
  • According to “Computation Center” CJSC data, in 2014 “Amberd 1” SHPP operated for 12 months and produced 3832692 kW electricity.
  • The projected length of derivation pipeline of “Amberd 1” is 2280.6 meters, diameter – 1020 mm, while the Public Services Regulatory Committee says the length of derivation pipeline is 2300 meters, diameter – 1200 mm.
  • The static pressure of “Amberd 2” SHPP isn’t mentioned in the project. According to the project, estimated pressure –268.9 m,  the estimated yield used by the SHPP is 2m3/s, projected capacity – 4.37 MW, according to the certificate issued by the Public Services Regulatory Committee, capacity – 6290 kW. According to the certificate issued by the Public Services Regulatory Committee, the factual useful delivery of the electricity is  9.5   million kWh, according to the project, the estimated production is 9.652 million kWh, duration of license - 24.10.2012- 24.10.2027, water usage permit - 22.08.2012- 22.08.2015.
  • The environmental flow of “Amberd 2” is laid down 0.1 cum/s in the water usage permit, while SHPP construction project says 0.06 cum/s.
  • The water usage permit says, “Amberd 2” SHPP is entitled to take water from the Ampur River for 6 months. The water usage permits bans to take water from May to October, in the irrigation season.
  • According to “Computation Center” CJSC data, in 2014 “Amberd 2” SHPP operated for 12 months and produced 5829817 kW electricity.
  • The projected length of derivation pipeline of “Amberd 2” is 4218 meters, diameter – 1020 mm, while the Public Services Regulatory Committee says the length of derivation pipeline complies with the project data, but not the diameter – 1200 mm.
  • Percentage Correlation of aggregate lenght (6498.6m) of “Amberd 1” (according to project 2280.6 m) and “Amberd 2” (according to project 4218m), SHPPs direvation with the lenght of Ampur River makes up 18.05%.

The lawyer of the expert group made enquiries to the relevant governmental departments about the lawfulness of the road constructed by  “Amberd HPP” LLC and blocking the access to the river. The reply of Nature Protection Minister issued on 28.07.2015 made it clear that the project documentation on the road construction hadn't been submitted by “Amberd HPP” LLC for the environmental impact expertise. The Real Estate Committee by RA Government said in its letter dated on 09.08.2015 that 9.9 ha land areas had been rented by “Amberd HPP” LLC from the pastures of Orgov community for the construction of SHPP and its premises, nevertheless, it turned out that “Amberd HPP” LLC hasn't registered any title to the road in Aragatsotn Region.

Given the aforementioned it can be concluded that “Amberd HPP” LLC has no title to the road running to “Amberd 1” and “Amberd 2” SHPPs and can't block it, as Article 23 of Water Code says that 'Each person is entitled to use freely the natural surface water resources and adjacent areas for recreational purposes...', while the road, blocking access to the river, violates this right.

There is a mess in the hydrological indicators of both “Amberd 1” and “Amberd 2” SHPPs.

In case of “Amberd 1”, the water laid down in the water usage permit is much more (almost 1.5-2 times) than the average flow of the river is for many years (50%) not taking into consideration even the environmental flow, which differs from the projected once twice.

In case of “Amberd 2”, the water intake figures also don't follow any logic. Adding this figure to the indicator of the environmental flow laid down in the water usage permit, we get a higher figure that the water available in the river for the particular month (for example, January or February). The indicators of irrigation water don't follow any logic either, as they don't fit in the water balance.

The proposals are limited because of insufficient monitoring results.

Proposals

To set only environmental flow as a standard for water usage of natural flow in its season regime given the environmental need. Differed water users shall adhere to water usage regime based on remainder principle following this priority – drinking water and irrigation – agriculture – industry – energy. 

“Amberd 1” small HPP

 
 
 
 
 
 
 
 
 

The material was  developed in the frames of “Supporting reforms in the sector of small hydro power plants through enabling a dialogue between civil society  and the Ministry  of Nature Protection for sustainable use of river ecosystems” supported by UNDP/GEF Small Grants Programme".



17:12 September 28, 2015


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