One of the spheres of "EcoLur" Informational NGO activities is studying the impact of small hydropower plants (hereinafter referred to as SHPPs) in the Republic of Armenia on the integrity of ecosystems, the impact of SHPPs on the socio-economic situation of the region, studies on the degree of compliance with the established environmental standards by the organizations operating SHPPs, as well as the submitting proposals for solutions to the social-ecological problems registered as a result of the study to the attention of the relevant bodies.
In 2014-2016, with the UNDP/GE support, “EcoLur” Informational NGO implemented in partnership Nature Protection Ministry "Support to SHPP-relating reforms through the dialogue of public and RA Nature Protection Ministry for Sustainable Use of River Ecosystems” project, during which 87 SHPPs were studies. Another 38 SHPPs were studies within the frameworks of the next project entitled "Supporting new reforms in SHPP sector through CSO-government dialogue" project. The SHPP database includes data on 125 small hydropower plants built on 70 rivers.
For each SHPP, 75 criterial on general, hydrological derivation, water intake, equipment, electricity generation, environment and social status of the population were tested.
The studies have revealed quite serious and generic problems:
· 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 serving as a basis for project operations,
· 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 because of low-quality equipment,
· Formation of SHPP cascades without assessment of cumulative effect,
· Failure to prescribe the statutori requirement to undergo environmental expertise for the construction of 0-1 MW SHPPs,
· By the decision of RA Government, increasing the threshold power SHPP standards up to 30 MW
· Lack of social responsibility towards the local population.
As a result of the implemented projects, a unified SHPP database has been established, institutional-legislative proposals for system reforms were proposed to the relevant bodies, some of which were adopted by them. In particular, RA Nature Protection Ministry has put into circulation draft law “On Laying Down List of Rivers Overloaded with Over 40% of Derivation Pipes and List of Rivers Prohibited for Construction of Small Hydropower Plants For Being Spawning Spots of Red-listed Endemic or Area-specific Fish Species", which bans the construction of SHPPs on 25 rivers.
"EcoLur" Informational NGO continues its monitoring in this sphere. In particular, special attention was paid to the changes detected in the activities of SHPPs built on the Yeghegis River in Vayots Dzor Region, Armenia after 2017, which are prohibited by RA Government's draft law.
Yeghegis River starts from the southern slopes of Vardenis Mountain, 3200 m high. The length is 47 km, the catchment area is 516 km2. The river valley is mainly gorge-like. It is fast-flowing, with many slides, waterfalls, has many tributaries. Feeding is mainly through melting (49%) and underground (39%), flooding in March-June. The average annual flow is 8.2 m3/s. At present, 17 SHPPs of 14 licensed electricity generation companies operate on its tributaries of the Yeghegis River, with a total capacity of 42595.2 kW, an annual production of 99.255 million kWh, and a total pipeline derivation length of 36576.5 m.
These SHPPs are as follows: "Yeghegis" and "Hermon" ("Elegis HEL" LLC), "Yeghegis-1" (“Bazenk" CJSC), "Karakaya" ("HAK HEK" LLC), "Surb Aghbyur" and "Vayots" ("SURB AGHBYUR" LLC), "Sunrise" (“SUNRISE ELECTRIC”CJSC)," “Yeghegnadzor" and "Yeghegnadzor SHPP" ("MINA-MAYA" LLC), "Vardahovit" LLC), "Goghtanik", ("HHNMS" LLC), "Yeghegis-3" ("SYUNYATS WATER" LLC), "Yeghegis-2" ("RAEL GES" LLC), "Nane" ("ARATES ENERGY" LLC), "Yegheg SHPP" ("YEGHEG HEK" LLC), "Tigran Mets" (RUS & HAR" LLC), "Artavan" ("JAHUK" LLC).
According to the official website of Public Services Regulatory Commission, 6 companies have been granted electricity generation licenses to generate electricity on the Yeghegis River and its tributaries, but as of June 20, 2020, these SHPPs are still under construction.
These are as follows: "Rind 2" SHPP by "ERIM ENERGY" LLC (on the irrigation system), "Yeghegnut 2" SHPP by "VTV ENERGY" LLC, "ELIS HPP" "Alice 2", "Tigran Mets 2" SHPP by "RUS & HAR" LLC, "Getikavank 2" SHPP by "GETIKHEK" LLC, "Khachkar 1" SHPP by "SERA" LLC (on natural streams). The total total design capacity of these SHPPs will be 19331 kW, and the total annual electricity production will be 58.95 million kWh, respectively. The total length of the river and its tributaries is 16625 m.
Excluding the SHPPs built on the tributaries feeding the Yeghegis River, as a result of the operation of the SHPPs built on the Yeghegis River itself, the river flow is derivated by 51.46%, and this figure will reach 76.69% in case of the planned operation of 4 SHPPs.
"EcoLur" information NGO continues its monitoring of the processes going on in the sphere. For that purpose, in February 2020, the organization sent an inquiry to RA Environment Minister regarding the policy and regulations implemented in the field of small hydropower plants. In response to the inquiry, the Ministry said that no water meters were installed on the environmental flows of the SHPPs, as according to the water use permit issued to the SHPPs, the water meters must be installed at water intake points.
It was also reported that water meters have been installed at the water intake points of 133 SHPPs, the installation of water meters at other SHPPs is underway, and changes in water intake volumes will be made after the expiration of the term of the water use permit. As for the hydrological data verification works, they informed that they have been evaluated for 3 water basin management areas. They noted that work is underway to establish a list of rivers prohibited for the construction of SHPPs, that water use permits will be reviewed in accordance with the requirements of the current legislation after the expiration of the term of the SHPP water use permits. Despite the measures taken, the SHPP operators continue to operate in violation of the law.
In July 2020, RA Environment Ministry, studying the situation, taking into account the level of overloading of SHPPs on the Yeghegis River, announced that it intends to review the water use permits (WUPs) of all small HPPs operating on the Yeghegis River. According to the announcement, the process hasn’nt been accomplished yet.
At the same time, RA Environmental and Mining Inspection Body only as a result of the inspections carried out in 2020 recorded cases of exceeding the water quantities issued by the water use permits. In particular, a fact of water intake exceeding the amount defined by the water use permit was recorded in "Yeghegnadzor" SHPP belonging to "MINA-MAYA" LLC. The company violated the requirements of Article 37 and Clause 2 of Article 114 of RA Water Code. An administrative fine in the amount of 200,000 AMD was imposed on "Mina-Maya" LLC. The damage to the environment amounted to 8,694,215 AMD.
In June 2020, Yegheg SHPP, owned by “Yegheg HEK” LLC, also recorded more water intake from Yeghegis River. As a result of the inspection, the damage to the environment in the amount of 3,813,821 AMD was calculated. Administrative proceedings have been initiated.
During its visit to the villages of Shatin and Yeghegis, located on the banks of the Yeghegis River in August 2020, EcoLur found out that there are complaints from the population about the lack of irrigation water on summer days. According to the locals, the water shortage is caused both by the work of the SHPPs located on the river during the irrigation season, and by the improper management of the general irrigation system. They noted a sharp decline or complete extinction of the red trout in the river. However, the residents of Yeghegis village connect the decrease in their drinking water flows with the activity of "Nane" SHPP built by "Arates Energy" LLC on the Aysas tributary of Karakaya tributary to the Yeghegis, which has been operating since 2014 and uses the water of their drinking springs. With the operation of this SHPP, the residents face big problems with the drinking water of their pet pastures and livestock.
The monitoring of "EcoLur" information NGO is continuous in that sphere: EcoLur will apply to RA Environment Ministry with a request to receive clarifications on the SHPP policy and processes in the sector in the near future.
September 14, 2020 at 11:12