EcoLur
EcoLur has collected proposals for the improvement of SHPP field and minimizing damage to nature. Reminder: on 4 June 2014 the presentation of “Socio-Environmental Analysis of SHPPs” research was held on 4 June 2014, where the proposals of EcoLur team were presented, as well as the discussion participants raised their own proposals, which we bring bellow:
Levon Galstyan, Pan-Armenian Environmental Front
1. To review RA governmental resolution no. 927-N “On setting demand in water for drinking and agricultural purposes, as well as setting assessments of environmental flows” dated on 30.06.2011 and to take hydrological, hydromorphological, hydrogeographical, hydrochemical, hydrophysical, environmental, seasonal and other peculiarities of the river basin when assessing and calculating environmental flow taking into consideration the fact that the river is a natural element providing long-term ecosystem services and not just a physical masses of flowing water.
2. To review all previously issued water permits after adopting a new method for calculating the environmental flow,
3. To stop the constructions of all SHPPs in progress and issuing new licenses unless the Armenian Government draws up complex and scientifically substantiated methodologies for various impacts arising in their construction and operation,
4. After developing methodologies we should review the permissibility of all operating SPPPs based on developed complex criteria.
5. The Public Services State Regulatory Committee shall calculate, substantiate and set a realistic tariff, which shall gradually decrease after returning investment and thus saved funds shall be directed to the development of other clean energy sources. The demand of having other alternative electricity sources shall be the prerogative for upcoming years.
6. To conduct examinations, including monitoring at “Environmental Expertise” SNCO to what extent the working projects of SHPP construction are discussed and which grounds and professional analysis are positive conclusions are issued on.
7. The transfer of SHPPs form Category B to Category C for unknown reasons in the new draft law “On Environmental Impact Assessment and Expertise” is very hazardous and impermissible, as it allows to give opinions in simplified procedure and without any serious assessments.
8. The water usage permits for the construction of SHPPs issued by Water Resources Management Agency of Nature Protection Ministry shall be examined in all details.
9. All operating SHPPs shall be equipped with an automatic system regulating the environmental flow, which all shall be switched to one common computer network, which will enable seeing and recording the water amount in the river at any time. This information shall be available online for any citizen.
10. To adopt proper legal acts, which will prescribe a provision that a positive environmental opinion and water usage permit needed for the construction of any SHPP will be issued only in case of availability of the positive opinion of the project affected community, environmental specialists and civil society. If the community definitely opposes to it, the competent governmental body shall issues a negative opinion to the site developer.
11. The construction of SHPPs in the specially protected areas of nature shall be definitely banned, as well as on the rivers, which are habitats to red-listed animal and plant species.
12. To immediately start monitoring in this direction and to give professional substantiations and conclusions, whether it’s permissible to pipe one whole river or to construct several SHPPs on one river. At last the negative environmental consequences of the construction and operation of over 300 SHPPs should be assessed for such a small country as Armenia is. In our opinion, it’s one of the most important issues, which currently worries not only civil society, but environmental specialists.”
Anna Shahnazaryan, Teghout Support Civic Initiative
To consider the problem in the context of energy policy and to give an assessment of the Armenia policy run in energetic security, so as to show to what extent the construction of SHPPs complies in the context of ensuring energetic security. Evidently the Armenian Government makes energetic security more vulnerable, which means that its substantiations for the construction of SHPPs are just a balloon.”
Vahagn Khachatryan, ANC member, economist
“The water cost is not calculated, it’s the problem, which is not solved, the cost of the water shall be included in the electricity tariff.”
Ashot Markosyan, Member of National Water Council, Deputy head of State Estate Management Department, Dr. in Economics, professor
“SHPPs shouldn’t be closed down, but the cost of the water shall definitely be paid. Why to invest capital in this field is rather clear, as it’s extremely profitable. We shall do in a way so as the public can benefit from it. Banks funding the construction of SHPPs shall demand also an environmental project. As our banks don’t pose such a demand, the state shall do it. The banks shall also have a function to supervise to see how these projects are implemented.”
EcoLur’s proposals
1. Under the Water Code of Armenia, to maintain the ecosystem balance of the river by determining the permissible standard for environmental flow. We are proposing to use Russian “ASSESSMENT CRITERIA OF ENVIRONMENTAL SITUATION FOR DETECTING ZONES OF ENVIRONMENTAL EMERGENCY SITUATIONS AND ZONES OF ENVIRONMENTAL DISASTERS: METHODOLOGY”. One of the chapters in this methodology refers to the exhaustion of surface water resources. It says, “Irrecoverable intake of surface flow has been taken as the main indicator of the degree of exhaustion of water resources. The standard is 10-20% of the environmental flow. Intake twice as much as the standard leads to the environmental emergency situation, while more than twice leads to environmental disasters.” Based on this, we are proposing to amend RA governmental resolution no. 927-N “On setting demand in water for drinking and agricultural purposes, as well as setting assessments of environmental flows” dated on 30.06.2011.
2. To annul RA governmental resolution no. 1300–A dated on 8 September 2011 “On Proposal to Set Maximum Capacity for Small Hydropower Plants”, where the capacity of SHPPs was increased from 10 to 30 MW.
3. To determine zones where SHPPs are prohibited, which include specially protected areas, forest areas, landslide zones and vulnerable hydrological areas.
4. To ban the construction of new SHPPs and not to renew the licenses of constructed SHPPs on those rivers, which are in critical and disastrous condition because of overexploitation.
5. To set a clear procedure, which will enable taking into consideration the opinion of the project affected community in the SHPP construction.
6. International financial institutions together with other stakeholders - Nature Protection Ministry, Energy and Natural Resources Ministry together with the Public Services Regulatory Committee shall bear responsibility for the adversary environmental and social consequences arising from the SHPP operation and violations of the domestic and international legislation.
7. To free the rivers flowing into Lake Sevan from SHPPs, to ban the construction of new SHPPs, to dismantle illegal SHPPs and not to renew the licenses of operating SHPPs.
8. To publicise all the official documents regarding to SHPPs – projects, minutes of public hearings, environmental expertise conclusions.
July 21, 2014 at 14:45