EcoLur Informational NGO has sent an open letter to RA NA MPs responding to RA Minister of Environment Erik Grigoryan's speech on SHPPs. The open letter says:
“During the question and answer session between the National Assembly and the Government of the Republic of Armenia on February 12, 2009, Minister of Environment Erik Grigoryan, answering the question of MP Hrant Ayvazyan on SHPPs, made a number of omissions and inaccuracies in connection with which EcoLur Information NGO gives its explanations.
In the minister's words, “… the writers of that text were writing this form 4 years ago, look at HPPs, etc., etc. Then they received a $70,000 grant, and then suggested that banks demonstrate some approaches in terms of building HPPs.”
EcoLur Informational NGO’s offer in terms of the banks was laid down in the handbook of "Support to SHPP-relating reforms through the dialogue of public and RA Nature Protection Ministry for Sustainable Use of River Ecosystems”, donor UNDP GEF, implemented by EcoLur in 2014-2016 (Երևան 2016), where among the 27 recommendations for SHPP reforms addressed to the Government of Armenia and SHPP owners, the following recommendations were made to development banks: "Provide loans for the construction of SHPPs subject to the requirements of the European Water Directive and monitor the process of implementation of those requirements." (page 22)
This proposal is related to the fact that small hydropower plants in Armenia are built with funding from international development banks and are included in the investment portfolio of development banks. In the case of financial lending, banks only guarantee a 100% loan repayment guarantee, without regard to the requirements of European legislation, which are mandatory for governments of the European Union (EU) countries. It should be noted that the main objective of the 2000/60 Directive on the Establishment of Community Water Framework in the EU Water Policy (Water Framework Directive WFD) the main aim is the achievement of a "good state" of water in all groundwater and surface water bodies. Monitoring and evaluation should be carried out to determine the actual status of water bodies. The WFD sets specific requirements for the status of water bodies.
Erik Grigoryan stated in his speech: "This National Assembly has introduced a number of restrictions on amendments to the Water Code developed by the Ministry, adopted a list of rivers prohibiting the construction of hydropower plants on these rivers, adopted a list of river sections where diversion pipes prohibited, red-listed passways, a number of restrictions.”
Reforms require having baseline and reliable data. For the first time this database was established within "Support to SHPP-relating reforms through the dialogue of public and RA Nature Protection Ministry for Sustainable Use of River Ecosystems” project in 2014-2016 followed by "Supporting new reforms in SHPP sector through CSO-government dialogue", donor - UNDP/GEF/Small grant program in 2016-2018.
The implementation of the second project was made possible by the letter of RA Minister of Nature Protection N 1/AA/11620 addressed to the UN Resident Coordinator/UNDP Resident Representative on 10.08.2016. UNDP/GEF SGP provided a total of $74,895 for these projects, and EcoLur Informational NGO's contribution totaled $46,610.
The SHPP database includes data on 125 small hydropower plants built on 70 rivers, 5 springs and 2 reservoirs with 75 criteria studied. The social impact of SHPPs was also assessed, in particular the conflict of interest between land users and SHPPs. The database has been provided to the Ministry of Nature Protection of the Republic of Armenia and is also published on www.ecolur.org “Small Hydropower, Energy” webpage.
For the first time, the river load on small HPPs was calculated using the methodology developed within the programs. It was proposed to ban the construction of new SHPPs on rivers with 30% load over SHPP pipelines. The fish world in 70 rivers, the impact of SHPPs on the fish world was described. The following issues have been detected:
• SHPPs from 0 to 1 MW capacity don't undergo environmental impact assessment, though their activities cause essential damage to river ecosystem,
• Insufficiency of SHPP operation transparency and supervision mechanisms,
• Absence of banned zones for SHPP construction, construction of SHPPs in water flow formation zones and specifically protected areas of nature,
• Incorrect hydroeconomic estimates in the project,
• Not ensuring the environmental flow and absence of control over the environmental flow,
• Functional incompliance of fish passways and fish-protecting nets, negative changes in the quantitative indicators of fish biodiversity and local fish species,
• Insufficient level of SHPP productivity and low-quality equipment,
• Absence of criteria and requirements required for equipment,
• Formation of SHPP cascades without assessment of cumulative effect,
• High threshold of capacity inadequate to SHPP descriptions – 30 MW,
• Numerous tree felling during SHPP construction and non-implementation of adequate tree planting,
• Detected SHPPs, which are constructed in water flow formation zone, which contradicts the requirements of the governmental resolution N 64-N dated on 20 January 2005 on the preservation of ecosystem sanitary, flow formation, underground water preservation.
• There are rivers, 70% of which is piped.
As a result of the project, the following documents have been developed:
• Draft law “On Making Amendments and Supplements to RA Water Code”, which proposes to have a new definition of environmental flow due to which the rational use of water resources will be ensured in SHPP operation.
• Draft law “On Making Amendments and Supplements to RA Code on Administrative Offences”, which envisages strict fines for not adhering to the preservation of environmental flow.
• Draft governmental resolution "On Approving Form of SHPP Environmental Passports and Guide of Provision", which aims to increase SHPP accountability, to introduce internal supervision (self-control) and mechanisms promoting SHPP operation.
• Draft governmental resolution “On Making Amendments and Supplements to RA
Governmental Resolution № 1343-N dated on 19 October 2017 “On Annulling RA Governmental Resolutions № 1680-N dated on 20 December 2012 and № 519-N “On Approving Checklists of Risk-based Inspections Carried out by Nature Protection and Soil Inspection Body of RA Nature Protection Ministry of RA””, which aims to establish control and to ensure effective environmental control in all the stages of SHPP construction and operation.
Dear Members of Parliament,
EcoLur Informational NGO, presenting the abovementioned data to you, concerned about the priority of environmental protection and rational use of water resources in the process of SHPP reform, looks forward to your involvement in the reform process and expresses its readiness to cooperate. An information video on the project is available at:
18:12 February 13, 2020