The letter of RA Acting Environment Minister Vahe Jilavyan № 2/10.1.5/7575 says, “Currently, "Gegharkunik" WUC has submitted an application for irrigation of 360.0 hectares of land in N. Getashen community from Argichi River through N. Getashen drain station, Getashen canal, Jrvezh brook canal, N. Demer drain station with 163.0 l/s aggregate water volume. I would like to inform you that the application for WP submitted by the WUC is under evaluation.
In June 2020, as well as in July, Gegharkunik WUC irrigated 11300.0 thousand cubic meters in N. Getashen community with the help of deep wells and aqueduct located in the community area, and in July about 15000.0 thousand cubic meters of water was provided. The WUC also draws water from the Argichi River. As for the problems arising due to the irrigation of the community land areas as a result of the water intake during the irrigation season by "Argichi" SHPP owned by "Hydro Corporation" CJSC, I would like to inform:
On July 3, 2020, Environment Ministry of carried out an investigation, which revealed that at the time of the studies, about 200-250 l/s of water was flowing in the Argichi River in Argichi SHPP area, and the drainage from the SHPP to the Argichi River was 700-800 l/s water. The water pumping station near the SHPP was not working, and "Argichi" SHPP, according to WP № 000031, does not draw water from the Argichi River in August.
The viewpoint submitted by you that the process of issuing the water use permit to "Argichi" SHPP was carried out with violations and public awareness was not ensured, I would like to inform that according to the regulation of public notice and publicity of the developed documents by Water Resources Management and Protection Body Public laid down in the governmental regulation № 217-Ն dated on 7 March 2003, the water use permit of Argichi SHPP in question was submitted by the authorized body to the public notice at the design stage, nevertheless, no remarks and suggestions were submitted in its regard within the set period.
I would like to inform you that the water use permit issued to Argichi SHPP is legal. In order to solve the problem of irrigation of the land areas in N. Getashen community, the community can apply to Environment Ministry with an application for a new water use permit submitting the documents required with this decision to that application.
After submitting an application for a water use permit by N. Getashen community of Gegharkunik region, Environment Ministry, in accordance with RA Water Code and RA Law on National Water Policy Principles, will review the water use permit of Argichi SHPP, whereas the SHPP will carry out water intake from the Argichi river by taking into account the priority of water users (ecology, irrigation).
I would also like to inform you that according to the last paragraph of Article 33 of RA Water Code, the term of water use permit № 000031 provided for the operation of Argichi SHPP owned by Hydro Corporation CJSC is considered to be extended."
RA Environment Minister’s response letter says, “...at the time of the studies, about 200-250 l/s of water was flowing in the Argichi River in Argichi SHPP area, and the drainage from the SHPP to the Argichi River was 700-800 l/s water.” In this regard, we would like to mention:
200-250 l/s water flow is 4-5 times smaller than 1000 l/s environmental flow laid down in the water use permit N 000031 provided to "Argichi" SHPP in 2014-2017, which, logically, could have increased after the adoption of resolution № 57-N of RA Government dated on January 25, 2018. According to this resolution, the environmental flow of the rivers should have increased, adding 33% to the existing flow as a "safety factor" to ensure the hydromorphological, oxygen and thermal conditions of the river, which ensure the survival and reproduction of aquatic organisms. As in the calculation of the environmental flow, the seasonal features and river supply should have been taken into account.
If the drainage from the SHPP to the Argichi River was 700-800 l/s of water, the environmental flow of the Argichi River was not preserved. It is interesting whether RA Environmental Protection and Mining Inspection Body, according to the arrangement reached as a result of the July 8 meeting with RA Acting Environment Minister Vahe Jilavyan, will inspect Argichi SHPP to find out the adherence to WP requirements.
Reminder: by the resolution of RA Government № 597 - N dated on April 23, 2020, water shortage was laid down in the territory of Sevan water basin, and in particular, the Minister of Environment is instructed to make temporary changes in the water use permits in terms of water use volumes and/or regime restrictions or moderations guided by the principles of water use priority laid down in the water legislation.
Although Article 33 of Water Code does not provide for the publicity of the extension of WP, it is recommended for the Ministry of Environment to be transparent, as well as to avoid misunderstandings, so that information on the extension of the WPs is published on the Ministry's website.
Referring to the unlawfulness of the construction of Argitchi SHPP mentioned in EcoLur's letter, the ministry noted the process of obtaining WP, while we speak about the EIA for the construction of the SHPP, which, according to the RA legislation, has lost its legal force. Argichi SHPP was built not in 2006 after receiving an expert opinion within a year, but started to be built in 2012 without a new environmental expert assessment.
17:29 July 13, 2020