The Ministry of Environment of the Republic of Armenia should reject the application for Water Use Permit (WP) for construction of “Loriberd 1” and “Loriberd 2” SHPPs on the Dzoraget River. Although these facilities are called SHPPs, they are actually hydro cascades with a projected capacity of 38.63 MW, which already exceeds the maximum threshold capacity of small HPPs - 30 MW.
Reminder: in 2011, the Armenian government set a 30 MW upper capacity threshold for small hydropower plants instead of 10 MW upper threshold widely common in the world, taking into account the interests of “DzoraHEK” HPP owners. “DzoraHEK” HPP was put into operation in 1927 and was privatized by the former President Sargsyan family. Owing to this decision, owners at no extra cost received additional income only from the difference in electricity tariffs generated by small HPPs and medium HPPs. Now this vicious decision, which should have been annulled long ago, is being tried to be used by other energy businessmen.
EcoLur participated in the discussion of water use permits for “Loriberd 1” and “Loriberd 2” SHPPs and submitted its negative opinion to the Ministry of Environment.
The opinion says: “The Ministry of Environment of the Republic of Armenia should reject "Lorva Amrots" LLC in providing water for the construction of “Loriberd 1” and “Loriberd 2” SHPPs on the following grounds:
1. 4 small HPPs have already been constructed on the Dzoraget River: Katnarat, Dzoraget 5, Dzoraget 6, DzoraHEK with a total derivation length of 10110 m. In 2016, the Ministry of Nature Protection of Armenia gave a positive opinion to the project for the construction of Dzoraget 4 SHPP on the Dzoraget. The Public Services Regulatory Commission, for its part, has granted a power generation license to Dzoraget 4 SHPP, and the SHPP is under construction at.
According to the EIA of this SHPP, the derivation pipeline is 3870 m long and 1220 mm in diameter. Operating 4 SHPPs and “Dzoraget 4” SHPP are taking 13980m section of the Dzoraget River or 20.86% of the river in the pipeline. The length of Loriberd 1 diversion pipeline from the new SHPPs will be 9100m, diameter - 3000mm, Loriberd-2 - 10500m, diameter - 2800mm. In case of construction of these SHPPs, 33,580 m of Dzoraget or 50.11% of the river will be taken into the pipeline. Applications for water use permits for small hydropower plants newly constructed under Article 30.1 of the RA Water Code are rejected on the rivers where the loads on derivatives are 40% or more. In this case, the construction of Loriberd 1 and Loriberd 2 SHPPs will exceed the 40% load threshold defined by RA Water Code. It should be noted that this calculation relates exclusively to the load on SHPPs constructed on the Dzoraget River and not to other water users, which in their turn, burden the river, and this should also be taken into account.
2. The Dzoraget River is classified as a fish-water aquifer in accordance with Appendix N 687 to the Declaration of the Council of Ministers of the Republic of Armenia "On Categorizing Some Water Facilities in the Republic of Armenia as Fisheries and Water Basins" adopted on 19 December 1991. However, small HPPs operating on the Dzoraget River have had a very negative impact on the river fish world. According to "SMALL HYDROELECTRIC POWER STATIONS OF THE DEBED RIVER BASIN AND ITS SIGNIFICANCE FOR FISHERIES PROTECTION" scientific article and the project outcomes of UNDP/GEF-supported “Support to SHPP-relating reforms through the dialogue of public and RA Nature Protection Ministry for Sustainable Use of River Ecosystems”, “Hydropower and hydraulic structures built on the Dzoraget River impede fish migration: as a result, the fish species living in the Debed River - Salmo trutta fario, Alburnoides eichwaldii, Barbus cyri, Capoeta sevangi, Capoeta capoeta capoeta, Alburnus filippii, Luciobarbus mursa, Gobiosp, Oxynoemacheilus brandtii, Leucaspius delineatus, Abramis brama, Carassius gibelio, Parasalmo mykiss, and Cyprinus carpio, most of which are characteristic of seasonal migrations, especially during breeding season, are unable to swim up the Dzoraget current to live and breed here.” The fish ponds of the SHPPs built on the Dzoraget River have not been reconstructed in accordance with the new construction norms and rules developed by the RA Urban Planning Authority, as these new standards have not been developed in Armenia. The new SHPP fish passages will also be built on the old construction norms and will not, in fact, have any functional significance. Thus, the Dzoraget has lost economically valuable fish species and may completely lose the fish world as a result of the construction of new SHPPs. Article 31 of Water Code of the Republic of Armenia stipulates that, when making a decision to grant a water use permit, the Water Resources Management and Protection Body shall take into account socio-economic and environmental impacts. The construction of SHPPs will disrupt the ecological balance of the Dzoraget River, as 50.11% of the river will be trapped in the pipes.
3. The data provided by “Lorva Amrots” LLC indicates that Loriberd 1 and Loriberd 2 SHPPs actually represent one system with a total capacity of 38.63 MW. This capacity exceeds the maximum capacity of SHPPs. It should be noted that the maximum threshold of 30 MW set for the small HPPs by the resolution of the Government of Armenia as of September 30, 2011 “On Establishing Maximum Power for Small Hydro Power Plants” has been valued by the expert group of “Support to SHPP-relating reforms through the dialogue of public and RA Nature Protection Ministry for Sustainable Use of River Ecosystems” as unjustified high, corruption risks were assessed as there is a significant difference in tariffs for small and medium HPPs. “Armenian Electric Networks” CJSC buys 24.276 AMD/kWxh of electricity generated by SHPP without VAT, which is twice as high as the tariffs for electricity produced by medium and large HPPs.
4. The Hydropower Development Concept adopted in 2016 provides for the construction of a 66- MW Loriberd HPP on the Dzoraget River. The construction of Loriberd 1 and Loriberd 2 SHPPs will reduce the capacity of Loriberd HPP from 66 to 38.63 MW. The economic benefits of building a low-capacity hydropower plant in the energy system are not appreciated."
16:06 February 11, 2020