EcoLur sent an opinion to RA Environment Ministry proposing to reject the issuance of a water use permit (WP) for the construction of "Lori Berd-1" and "Lori Berd-2" SHPPs on the Dzoraget River.
EcoLur's opinion says: “We propose to reject the water use permit applications submitted by "Lori-Amrots" LLC for the construction of "Lori Berd-1" and "Lori Berd" -2 small hydropower cascades on Dzoraget River, Lori Region, with the following substantiation.
1. On 8 April 2021, the Armenian Government adopted resolution 488-N "On defining the list of rivers prohibited for the construction of small hydroelectric power plants conditioned with being spawning sites for red-listed or endemic fish species or overloaded with derivation pipelines by 40% and over”. One of 25 rivers listed in this resolution is the Dzoraget River, tributary to the Debed.
2. 4 SHPPs have already been built on the Dzoraget River: "Dzoraget 4" SHPP is under construction. Existing 4 SHPPs and "Dzoraget 4" SHPP, which is under construction, are taking 13910 m of the Dzoraget River, or 20.76% of the river, into the pipeline. The length of the diversion pipeline of "Lori Berd 1" from the new SHPPs will be 9100 m, the diameter - 3000 mm, "Lori Berd-2" - 10500 m, the diameter - 2800 mm. In case of construction of these small HPPs, 33,510 m of Dzoraget section or 50.01% of the river will be taken into the pipeline.
Applications for water use permits for newly constructed small hydropower plants under Article 30.1 of RA Water Code are rejected in case of construction on rivers where their load through diversion pipes is 40% more. In this case, the construction of "Lori Berd-1" and "Lori Berd-2" SHPPs will exceed the 40% load limit of the river as set in RA Water Code. It should be noted that this calculation refers exclusively to the load on SHPPs built on Dzoraget, not to other water users, who, in their turn, load the river, which should be considered.
3. The Dzoraget River is classified as a fishery water body in accordance with Annex 687 of the Decision of the Council of Ministers of the Republic of Armenia adopted dated on December 19, 1991 "On classifying certain water bodies of the Republic of Armenia as fishery water basins". However, the small hydropower plants operating on Dzoraget have had a very negative impact on the fish world of the river. Hydropower and hydraulic structures built on the Dzoraget River impede fish migration.
As a result, the fish species living in Debed (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, Cyprinus carpio), most of which are characterized by seasonal migrations, especially during the breeding season, they do not enjoy the opportunity to go up the Dzoraget River to live and reproduce here. As a result, Dzoraget has lost fish species of economic value, and may completely lose the fish world as a result of the construction of new SHPPs. Article 31 of RA Water Code stipulates that, when making a decision to issue a water use permit, the authorized body must take into account the socio-economic and environmental impacts. The construction of SHPPs will disturb the ecological balance of Dzoraget.
4. A certain section of “Lori Berd-1” SHPP pipeline will pass near the natural monument called "Getnandzav" cave tunnel, which is located 40-50 m from the left bank of the Dzoraget River at an altitude of 35-40 m. According to Article 30.1 of RA Water Code, applications for water use permits for newly constructed small hydropower plants are rejected if the construction of small hydropower plants is envisaged on rivers within a radius of 150 meters of natural monuments."
April 19, 2021 at 15:48