EcoLur
The Nature Protection Ministry didn’t accept public proposals on the reforms in SHPP sector, which were submitted to the Armenian Govoernment after presenting EcoLur’s report entitled “Socio-environmental Analysis of SHPP Impact (see http://ecolur.org/en/news/water/ecolur-to-send-proposals-on-small-hpps-to-head-of-national-water-council-ra-prime-minister-hovik-abrahamyan/6438/). Out of the whole package the Ministry selected the proposal on regulating the environmental flow, which is currently laid down in the governmental resolution N 927 N dated on 30.06.2011. The ministry reply letter N 5/12.1/52301 dated on 05.08.2014 gives the definition of the environmental flow in accordance with the governmental resolution and particularly says, “…The calculations showed that the data on the environmental flow estimated under governmental resolution 927-N dated on 30.06.2011 exceed the indicators laid down under the former governmental resolution N 592-M dated on 22.05.2003 by 30-40%...Your proposals will be taken into consideration when developing the management plan of water resources…” the letter says.
We would like to draw the attention to the fact that the notorious resolution on the environmental flow has been criticized many times both by the public and the Armenian-Norwegian program on reforming SHPP sector, and the international experts – European Association of SHPPs, OSCE, local population, who had opposed to the construction of SHPPs etc. Besides, the definition lacks the assessment of river ecosystems, there is no substantiation of the data on the river parameters and the load on them, no damage assessment.
That’s why, the public proposed the government and the ministry to use the methodology on detecting zones of extreme environmental situation and environmental disaster developed by the Russian Federation, which will help to determine the load on the rivers (http://ecolur.org/files/uploads/pdf/metodika.pdf).
August 14, 2014 at 15:58