Hydropower in Bulgaria - modern history and problems.

Present status of the legal framework
 At first sight, the legal framework makes a very good impression. It is written in such a way just to be well accepted by the EU administration when checked for compliance and harmonization with the European directives. However, there are loopholes left everywhere. After a detailed study of the legal framework it shows a lot of gaps and ambiguities. Everyone can interpret it as he pleases and as it suits him best. Here are just a few examples: the Ordinance for fish passes design as well as the Methodology for the E-flow determination are not ready yet, many years after the deadline for their release acc. to the BG Fishing and Aquaculture Act and the Water Act has expired; The protected areas have not yet been announced under the provisions of the Biodiversity Act and the Habitats Directive; HPP owners have to study and report on the biological state of the rivers themselves, rather than these checks to be carried out by the state authorities instead; and many more. Here we will focus on only one of the most important issues:

Acc. to art 118j of the Water Act HPP are allowed on rivers with an average multiannual /long term/ flow bigger than only 100l/sec and the E-flow is determined as 10% of the average multiannual /long term/ flow, but not less than the average monthly flow within 95% reliability. Will any living creature survive in a river that runs with 10% out of 100l/sec?

Another major problem is that the HPP operators do not release a single drop of water into the river during low water - when they shouldn't be working at all. 

 Article 118j of the WA has to be amended: the water quantity must be increased significantly and must be also linked to the minimum average monthly flow - because it guarantees the life in the river, but for a very short period of time. An absolute minimum flow of at least 70 l/s must also be introduced in the definition of the E-flow. As a rule, below this value, life does not survive in a river.
Water Permits
  • For Water abstraction (issued by the River Basin Directorates (RBD): even in Natura 2000 Habitats Directive Sites, disregarding a special ban set in Article 118j of the WA, as well as a ban in the RBMPs. Example - Rumyantsevo 2 HPP
  • Assessing the necessity for an EIA (issued by RIEW): - very often it is decided that an EIA is not necessary. Even in cases when the competent authority has decided that there is a risk for significant adverse impact on a Habitatas Directive site. Example - Rumyantsevo 2 HPP again.
  • E-flow - the Methodology for it does not exist. The requirement for a minimum E-flow bigger than the average monthly flow within 95% reliability is always skipped. There are many mistakes on the E-flow determination, always in favor of the operator, and the state does nothing about it. Examples - Petrovo HPP, Rumyantsevo HPP and many many others. The E-flow strategy should be subject to a thorough reconsideration.
  • For each river a water permit should not be issued until all the necessary hydrological data becomes available.
  • There are many cases of direct arrogant lies in the investment Plans. In the case of the Dolna Studena HPP on the Yantra river the BDDR has issued a Water Permit and the director of RIEW Ruse denied authorization of the IP, pointing out to the BDDR that there is a ban for this river in the Danube Region RBMP. A state official - the director of RIEW Ruse, Mrs Lilia Atanasova, did her job acc. to the law and got fired afterwards.
    The authors of the platform express their deep respect for Mrs. Atanasova..
Design
  • It is a Tragicomical situation. The main problem is - the investors are dreaming to produce as much electricity as possible. The designers literally lie about the return of the investment. So the second is willing to cheat to get more money from the investor, and the first is dreaming to be cheated. This can only happen if all the water in the river is fully 100% caught.
  • Fish passes - in BG we have the most stupid fish passes on planet Earth. Just watch what's happening on the Davidkovska River.
  • Even when the Fish Pass is properly designed, it provides only for the upstream migration of the fish. The downstream migration is still an unsolvable problem. Anyone who's interested can read the following document: POSITION_HYDROPOWER_AND_NATURA2000
  • For the Run-off-river HPPs, there are cases of a very wrong location. For example - the Elena HPP near the village of Hayredin. Many houses on the lower bank of the river in the village got flooded, due to the groundwater raise because the lake is right by the village.
Funding
  • The Banks should know better what kind of nature destructive business they are financing. Those investment plans are absolutely false in terms of their effectiveness. They rely only on the water in the river being 100% full time caught and that breach of the law will not last forever!
  • The European Commission should know better what kind of business it supports - through the EU INEA and through the Kozloduy Decommissioning Fund. We managed to stop the Iliyna HPP of the Rila Monastery in 2016 and will inevitably stop in court the Yadenitsa dam in 2017, to give another lesson to all who were involved
Construction
  • Some HPP remain unfinished in the middle of construction. Examples - Eleshnitsa HPP near Sajdenik, Dulga Reka HPP a.o.
  • In many cases the water catchment, or the power house, or both, are located on spots in violation of the Water Permit coordinates, aiming to increase the water head or to catch more water. The state authorities are doing nothing about it.
  • Sometimes the dam walls are built with a bigger hight. All the violations are rewarded with a 5000€ fine and afterwards the HPP is permitted to further operate.
  • All of the above can only happen with the complicity of the state in the crime.
Modus operandi
  • In many cases the rivers get totally dry.
  • In the rest - only a very small water quantity is running in the river below the catchments, much less than the E-flow set in the Water permit.
  • In most of the rivers there isn't a trace of life, let alone the possibility for fish migration. There isn't anything to migrate upstream the river anyway.
  • On irrigation channels - the HPP operators do not let the water to be used for agriculture. Example - Katuntsy HPP, Petrovo HPP in the past.
  • The problem of accumulated silt in the ponds turns every lake into an ecological bomb with delayed detonation. Two were already blasted - Lakatnik HPP and Luna HPP, to kill tons of fish and other aquatic species for about 30 kilometers downriver the Botunya and the Iskar rivers
  • The old HPP from socialist times - they were built to cover only the peak electricity consumption hours. All of them have equalizers that were supposed to be filled slowly during the day, using the water only in the peak hours. Nowadays those HPP work full time, full power, using the entire water in the river. Example - Petrovo HPP.
  • During low water all the HPPs should not be taking any water from the river at all and they are taking every drop there is.
  • Dry riverbeds get clogged with bushes, trees and other vegetation, thus increasing flood risks. Examples - Sveta Petka HPP, Rumyantsevo HPP.
  • From a dry riverbed clogged with bushes cannot be taken any water to extinguish forest fires in the mountains.
Control
  • There isn't such a thing in Bulgaria at all. In June 2013 WARBD carried out 133 checkups and managed to catch no one that violates the law?
  • Sometimes the RBDs do not react to signals at all. Examples - Sveta Petka HPP and Etropole HPP.
  • If they follow up a signal
    • On the other day the river is not blocked because the operator got warned. Example - Yankulitsa sHPP
    • The fines for registered infringements are so small that are not worth even mentioning. This presents a breach of the EU WFD - quote: the penalties must be effective, proportionate and dissuasive...
    • RBDs do never check if their prescriptions were followed. Examples - Manastirska HPP, Rumyantsevo HPP and many many other.
  • Under article 174 of WA - HPP operators must check and report the status of the river stretches between the weir and the turbine house of HPP on their own. In other words - potential sinners should self-check and self-report themselves for the sin - if and when they succeed to get caught - by themselves again, that is. Is there any sense in that?
  • There is not a single fish pass checked whether the migration of the fish is provided for.
  • The penalties under Articles 199 and 200 of the Water Act have never been imposed.
  • Two letters of objection by the Chamber of Engineers have totally been disregarded by MOEW.
Access to information
  • RBDs are deliberately hiding the truth. The coordinates of many HPPs were false and we had a very hard time to discover the exact locations of the water catchments.
Suggestions for improvement

In the BG version these are thoroughly described. More info can be found here: POSITION_HYDROPOWER_AND_NATURA2000 

  We will disclose here only the major issues regarding the control and the permits' regime:
  • 1. Implementation of modern solutions for control of the water catchments such as: sensors and automatics for the E-flow, online videocontrol by the RBDs etc..
  • 2. Mobile group of control executives with MOEW to carry out combined checkups with NGOs. The RBD checkups will never be effective.
  • 3. Nationwide monitoring programme to study the ecological river status caused by the hydropower impacts, executed by the state, not by the operators. If there is no life in the river discovered - the HPP must be closed.
  • 4. During low water periods hydropower production must be blocked by the state.
  • 5. Hydropower should not be rewarded with those subsidies! It is anything but green energy. It is in the darkest shades of black.
  • 6. The E-flow determination should be improved significantly. At present rivers are sentenced to everlasting drastic low water status. 10% or 95% reliability is nothing and not a living creature can survive in the river.
  • 8. In the Water Act the E-flow definition must refer to the water quantities under the natural flow conditions. At present we have here many HPPs that are working on the E-flow, released by other hydropower units.
IMPORTANT
  The platform shows several cases of properly operating HPPs that are following the law and the ecological regulations. They are assigned with a camera in a green circle. Meaning that we are exposing not only the bad, but the good examples too - they are assessed only acc. to the legal requirements for the fish pass and the E-flow released at the moment of the visit!
MORE IMPORTANT
  • The modern myth about some still remaining hydropower potential in BG is dead. Created by unscrupulous hydrologists and hydro-technicians, hoping to use their knowledge and skills to earn more money, and embraced by the dreamers for quick and easy profits, it has led to nearly 900 spots located along the rivers for new HPPs' water catchments. Every single spot at each small stream has a holder who has acquired the rights granted by the Basin Directorates - everyone can guess how and why. HPPs that have not been built up yet are preserved for the hope that the rights may be sold one day.
  • All the hydropower potential there once was in our country, was used during the socialist times and there is nothing left around here. And it was designed only to cover the peak hours of electricity consumption. Such a potential have countries like Switzerland, Austria, Italy, etc. We have nothing like that. In our small rivers with their unstable runoff during the year, the investment for HPPPs that are following the legal requirements for the E-flow, are able to return the investments for at least twenty years. Only if the conditions for the back purchase of the energy do not change over the years and only if they are high water years. Actually, most of the new HPPs must not be working at all during the dry months of the year, but they do not seem to know it yet, and they seemingly do not want to learn it. But they will one day.
MOST IMPORTANT
  • At the moment some 260 HPPs are in operation. We have already shot some 170 of them. Less than 10% are following the rules to some extent. The rest are drastically breaking the law. There are many stupid projects too! And some 600-700 new HPPs are on their way! We've had enough of hydropower here!
  • '''In accordance with art.117, 3, 4 of the WA, due to the absence of any reasonable National Standards for hydro-technical design and construction of hydropower plants - we believe that a temporary Moratorium on any further HPP approval procedures including construction permits for new HPP is essential - until those Standards are prepared and introduced. Thus all existing, but not implemented yet, or future projects shall be brought into conformity with these Standards and only then shall be approved for further development.
  • We also believe that prior to the preparation and implementation of National standards - a nationwide programme for ecological impact assessment of all existing HPP should be carried out - to get a clear picture of all the benefits and damage they produce, in order to draw the necessary conclusions for the future..'''
  • The reasons that led to the current situation must also be revealed and the perpetrators have to take responsibility!
  • We have seen so many mistakes in the existing HPP - that must not be multiplied in the future 700 HPP, by any means.
Actions taken insofar:
Future actions
  • Long term goal - Proceedings with the EC for the drafting of uniform EU rules on the design, construction, operation and control of HPP. National specifics can be taken into consideration by relevant national applications - the same principle as the implementation of the Eurocode design system for all the other buildings and facilities.
  • Final goal - all the existing HPPs are brought into conformity with the EU regulations.


Page last modified on 20.10.2017 11:22