Garik Pogosyan, resident of the village Shatin:“The river came from above and entered the green building, got out of there, entered this other pipe, this one goes to another building. If there is one turbine in the small hydropower plant (SHPP), it means there is one hydropower plant (HPP), if there are two turbines, it means there are two HPPs. Yet there are SHPPs here that work with three turbines”,-said resident of the village Shatin Garik Pogosyan.
Garik Pogosyan from Shatin shows 19 SHPPs built on Yeghegis River which take water of the river from residents of 12 settlements of Yeghegis enlarged community leaving them without drinking or irrigation water. Even fish in Yeghegis River are doomed to extinction.
For centuries, people built their homes near freshwater sources. The residents of Yeghegis enlarged community are no exception. About 6947 inhabitants earn their livelihood through cattle breeding, agriculture and gardening. The residents of these communities face water problems, since the latter flows through the pipes serving only the interests of former and current officials and generals.
Resident of the village Shatin Avo Hovakimyan told us about water problems․
“I demand water! Maybe I sow barley, wheat or watermelon. If it's arable land, I must have water. But how should they give it, if the head of the Vardahovit community Artur Stepanyan himself constructed a small HPP on top of my land area. Would he stop his SHPP to give me water”?
Since 2016, the Government of the Republic of Armenia has established extra-favorable conditions for SHPP owners, who can operate SHPPs and pay no taxes for the used water.
Inga Zarafyan, President of Ecolur NGO: “Many SHPPs that obtained licenses for water use, do not pay any water tax. It was very tempting for businesses. They built those hydropower plants. Meanwhile the calculations for reservoirs were incorrect. As a result many SHPPs work only during flood seasons. It means that the rivers are filled with SHPPs that do not work”.
According to Article 5 of Water Code, out of 24 points of basic principles of management, use and protection of water resources and water systems, the priorities are as follows:
1)satisfaction of basic vital needs of present and future generations
2)maintaining and increase of volumes of national water reserve
3)protection of aquatic and related ecosystems and their biological diversity, as well as recognition of the integrated and interconnected relations of land, air, water and biodiversity.
Only the 11th point considers rivers as a source of energy.
In reality the diametrically opposite is happening in Armenia. The point which obliges SHPPs to leave enough water in the rivers sufficient for human needs- this point is not included in water use permits or contracts.
Garik Papoyan: “There is a problem with drinking water in the village. Many times we have applied to the service company Veolia with letters and calls, but no result. Once they came to cut the water for illegal consumers. People agreed. They suggested cutting it off, instead demanding legal water pipeline, installment of water meters. Yet the company left and did not return. Today all Yeghegnadzor has no drinking water. People are thirsty. They dream of a glass of drinking water, while the water of this beautiful river flows through the pipes of SHPPs supporting their businesses”.
The existence of 19 SHPPs on one river, the permits issued by the state make it impossible to leave water in the river for the needs of communities. The governor of Vayots Dzor region of Armenia Ararat Grigoryan replied to the inquiry of ‘Green Armenia’ Environmental, Educational NGO regarding the violations by the SHPPs on Yeghegis River, mentioning that at least 13SHPPs out of 19 didn't comply with the norms of water use permit.
It mentions that technical re-equipment was implemented, but no new EIA has been carried out, ecological flow and sufficient living conditions for fish were not maintained.
Avo Hovakimyan, resident of the village Shatin: “Because of SHPPs our nature dried up, we can't properly live. I have taken many steps. For six months I’ve slept under the walls of the village municipality. I fought against HPPs”.
The governor of Vayots Dzor Ararat Grigoryan mentions in his reply that based on the results of inspections in SHPPs on the river Yeghegis and its tributaries decisions will be made to prevent the catastrophic situation in the river.
The Ministry of Environment in its turn informs that the water flow through ‘Arpa-Sevan’ 2nd tunnel should be ensured for satisfying the irrigation and drinking demands of the communities, as well as the ecological flow should be maintained, only after which water should be distributed to SHPPs.
Inga Zarafyan President of Ecolur NGO: “Those SHPPs that absorb all river water will be obliged to operate without any violations. They should leave enough water in the river. But the question is whether there will be enough water left in the river if all SHPPs operate”?
Yeghegis River has 40% of load by SHPPs. In its response the Ministry of Environment cites the Article 30․1, which states: applications for water use permits for new small hydropower plants are rejected if the construction of the SHPP is planned on rivers the load of which with diversion pipes is 40% or more. According to Government decision No 488 adopted on April 8, 2021, applications for water use permits for small hydropower plants are also rejected if there are spawning sites of endemic fish specific to the area or listed in the Red Book.
- There are indications that the physicochemical composition of water in Yeghegis River has changed. This is unprecedented. Before the river would slowly return to its former composition despite the floods or other events. But if the physicochemical composition of the river is changing, it means the river is dying. The water temperature has also changed since overheated water comes out of some turbines. It means we have overheated water in the whole river. There are fish species that are used to cold water, and yet their habitat has changed. Will these endemic fish species survive? Hardly.
An interdepartmental working group has been set up for studying the activities of the hydropower plants on Yeghegis River, for identifying problems and developing proposals for the amendment of relevant legislation.
We learn from the reply of Vayots Dzor Governor Ararat Grigoryan that particularly Gornar SHPP had no waterproof well for wastewater disposal envisaged by the project. There are no water meters at the water intake points, which makes it impossible to obtain reliable information on the volume of intake from Arpa River. Gornar SHPP is operated by ‘Green Energy America Concern’, which since April 22, 2020 has been owned by ‘Environmental Control Products’ located in Wyoming, Pioneer Ave, Cheyenne, USA. We also learn from the reply of the governor that Yeghegis 2 SHPP had a fence installed instead of a fish protection net.
Below the water intake the river bank was very polluted. Yeghegis 2 SHPP is operated by "Rael GES" LLC, 36% shares of which belong to Gevorg Machanyan - the Executive Director of ARMSWISSBANK since its foundation. Gevorg Machanyan is also the President of Swiss-Armenian Business Association and member of the Board of Switzerland-Armenia Joint Chamber of Commerce.
Another 16% of shares of “Rael GES” LLC belong to Donara Abrahamyan, who, according to an article published by investigative journalists at Hetq, is the sister of Colonel Serob Abrahamyan, the former head of the technical support department at the Ministry of Defense.
The norms for the fish passages were also not observed in Goghtanik SHPP. From the Fact Investigation Platform (FIP) we learn that Goghtanik SHPP operating on Yeghegis belongs to Hayk Suvaryan - husband of former Prime Minister Tigran Sargsyan’s daughter.
"Karakaya SHPP transformers had no oil catching system. Oil leaks were detected. One of the pipelines was not buried, the other was partially underground. The fish protection net was also missing. The entrance of the water intake pipe was closed with a fence”, mentions Governor Ararat Grigoryan’s reply. Karakaya SHPP is operated by "HAK HPP" LLC - 100% owned by Sarkis Avetisyan. His registration address is in Russia, Nakhodka, Kreshenskaya. Before that, the SHPP belonged to the residents of Vernashen village, husband and wife Samvel Isakhanyan and Tsoghik Karapetyan.
According to the governor's reply Yeghegnadzor and Yeghegnadzor 1 SHPPs also don’t have fish passages as envisaged by the project. Yeghegnadzor SHPP և Yeghegnadzor 1 SHPPs are operated by "Mina-Maya" LLC, where Vachik Kokobelyan has 100% ownership. The latter is the brother of Khachatur Kokobelyan- the leader of ‘Free Democrats’ political party. Khachatur Kokobelyan was the member of the National Assembly during its fifth convocation. In 2017 he ran for Free Democrats in parliamentary elections, but did not get enough votes. Until May 20, 2019 50% of "Mina-Maya" LLC was owned by Narek Sargsyan, the son of Lyova Sargsyan who is the brother of former RA President Serzh Sargsyan.
In response to the NGO's inquiry, it was mentioned that another SHPP- Yegheg, allowed for sufficient water flow. But the director explained that the fish passage and the section for ecological flow were closed with a wooden barrier to catch fish. In 2019 a modern unit was installed in the HPP building, which is considered a technical upgrade. According to the EIA law a new examination should have taken place. But no such application was submitted and no positive expert opinion was available.
Hrachik Vardanyan's shares in Yegheg SHPP are 39%, another 21% is owned by Sofik Vardanyan, and Robert Okhanyan owns 30% of shares. Sofik Vardanyan's son Suren Karayan became the Minister of Economy in 2016 by the decision of then President Serzh Sargsyan. It should be noted that it was since 2016 that permits were issued for HPP construction with the most favorable conditions for business activity.
Governor Ararat Grigoryan’s reply also mentions that "Getikvank SHPP did not take water from the left tributary of Yeghegis because the second turbine was not working. According to the director, the fish passage on the upper section was closed due to the sludge and the volume of the ecological flow was little".
Yeghegis 1 SHPP was also among cases with violations registered by the Regional Administration. Above the main water intake structure, there were sand hills in the riverbed that were removed from the river course showing that the riverbed was changed – an activity prohibited by the Water Code.
This SHPP also had 2 turbines, which were made in Bulgaria by Mavel brand. But they had to be Chinese. This is considered as a technical upgrade and according to the EIA law, technical-technological upgrades that can have an impact on the environment are subject to environmental impact assessment, as mentioned in the response of the governor.
"Yeghegis 1" SHPP is operated by "Bazenk CJSC". Information on this company is not available in the State Registry. There were inconsistencies regarding technical and construction aspects in Yeghegis 3 SHPP. The last step was too high, impeding the movement of fish upstream. Yeghegis 3 SHPP is operated by "SYUNYATS Water" LLC, where Naira Sargsyan owns 100% of shares.
In Surb Aghbyur SHPP bio-toilet for domestic wastewater disposal was not installed. The SHPP is operated by "Vardahovit" LLC. According to the State Registry 100% of shares are owned by Narek Hovsepyan, the son of former RA Prosecutor General Aghvan Hovsepyan. Narek Hovsepyan is registered in Yerevan, Malatia-Sebastia, Tserents str.5, flat 89. The former Prosecutor General is also registered at the same address. Aghvan Hovsepyan's other son Misak Hovsepyan is also in the list of directors. As a reminder,a criminal case has been launched against former prosecutor Aghvan Hovsepyan.
According to another project a gradual fish passage is envisaged on the right side of the concrete dam of Vardahovit SHPP, but in reality the fish passage was missing. The ecological flow was ensured partly over the dam and partly through the sludge filter, which, however, would not be possible during drier seasons. There were no fish protection nets as well.
Vardahovit SHPP is operated by "Vardahovit" LLC. Here as well the former RA Prosecutor General Aghvan Hovsepyan's sons Misak and Narek Hovsepyan are shareholders. Misak Hovsepyan has a 100% share. Before that 42.5% of shares of this SHPP belonged to Zangezur Eximp Company and other 42.5% of shares belonged to Karine Sargsyan. Another 15% of shares belonged to the wife of Vardahovit's Administrative Head- Agnesa Stepanyan.
Vayots SHPP is operated by "Surb Aghbyur" LLC. There was no fish passage in Vayots SHPP. There were fences for catching garbage which would not block the entry of small fish. Aghvan Hovsepyan's son Narek Hovsepyan has a 100% share in Surb Aghbyur LLC.
In its reply the Environmental Protection and Mining Inspection Body mentions that there are 35 small hydroelectric power stations in Vayots Dzor region, 14 of which are located on Arpa river and its tributaries, 19 SHPPs are located on Yeghegis river and its tributaries, 1 SHPP is located on the water discharge point of the pond of Jermuk town park and 1 SHPP is on Chiva-Rind irrigation water line.
As a result of inspections, environmental violations were registered at "Her-Her-1" SHPP belonging to "Firma Gakh" LLC, at "Surb Aghbyur" and "Vayots" SHPPs belonging to "Surb Aghbyur" LLC, at "Arpa" SHPP belonging to "Arpa Energy" LLC, at "Yeghegis-1" SHPP belonging to "Bazenk" CJSC, at "Yeghegnadzor" SHPP belonging to "Mina Maya" LLC, at "Yegheg" SHPP belonging to "Yegheg" LLC, at "Nane" SHPP owned by "Arates Energy" LLC, at "Elegis" SHPP belonging to "Elegis HPP" LLC, at "Sunrise" SHPP owned by "Sunrise Electric" LLC .
"Elegis" SHPP is also built on Yeghegis river. This SHPP was not mentioned in the reply of Vayots Dzor Governor Ararat Grigoryan, yet it was included in the response of the Environmental Protection and Mining Inspection Body among the companies that committed violations.
"Elegis" SHPP is operated by "ELEGIS HPP" LLC. According to the State Registry, Mayis Mkrtchyan from Rind village has a 50% of shares and Garik Shahgaldyan from Arshaluys village of Armavir region has another 50% of share. Mayis Mkrtchyan is the brother of Bishop Abraham Mkrtchyan- the primate of the diocese of Vayots Dzor.
Following the amendments to the Water Code in 2021, SHPPs will now have to operate under new Water Permit Regulation which implies that SHPPs are obliged to leave 20% of water in the river instead of the previous 5%.
Inga Zarafyan, President of Ecolur NGO:“SHPP operation licenses are expiring.With the new law they are obliged to get permits. The new decision is more favorable, obliging for environmental flow of 20-30%.
This implies that dozens of SHPPs built on overloaded rivers will no longer be able to operate since they will not be able to meet the government's new requirement.
Author of the film - Tehmine Yenokyan.
Green Armenia Environmental Education NGO