Dear friends from EBRD, EIB and the World Bank,
I really hope that most of you remember our communication on some of your guiding documents concerning Hydropower development all over Europe, with a special focus on the Balkans.
Today, March 14th, is the International Day of Action for Rivers /former International Day of Action Against Dams and for Rivers, Water and Life/
On this special day I am so happy to share with all of you some great News coming from the European Union in the following special EU report - "Financing a sustainable European Economy":
There is a Technical Annex to the report, which can be found here:
To our view, the most important issues concerning the existing hydropower pressure all over Europe, including the Balkans, as well as any future development, can be found on pages 224-226 of the Technical Annex. Here is just a short citation:
"Construction of new hydropower should not lead to increase fragmentation of rivers, consequently refurbishment of existing hydropower plant and rehabilitation of existing barriers should be prioritised. Construction of small hydropower (<10MW) should be avoided."
Furthermore, the experts call for cumulative impact assessments "identifying and addressing any significant regional or basin-level environmental and social impacts, in compliance with the Water Framework Directive"
So, we would like to point out the fact that as of today all the guiding documents of the recipient banks concerning any future hydropower financial support are obviously out of date.
The documents in view are:
1. Operation and Maintenance Strategies for Hydropower: Handbook for Practitioners and Decision Makers - WB
2. Environmental, Climate and Social Guideline on Hydropower Development - EIB
3. Environmental and Social Policy /ESP/ - EBRD
We've had our written positions on the above documents shared with the EIB and the EBRD at the time, together with a clear warning that small hydropower should not be financed either directly and/or through Financial Intermediaries /FIs/ anymore due to its devastating impact on the riverine and riverside ecosystems, as well as on the local people's wellbeing, with absolutely no consequent benefit to the society.
We've had a fruitful meeting with the EBRD team of decision makers on the matter in Belgrade too, which has led to a significant "change of wind" towards small hydropower /to my knowledge/, or should I say to a "change of the water flow" in the hydro turbines...
However, a total ban was not imposed, as far as I know.
As for the World Bank, we have had no written communication, but a meeting was held recently in Sofia to discuss the future River Basin Management Plans of the four River Basins in Bulgaria, on the preparation of which the WB team is taking part as a consultant.
Therefore, we hereby strongly urge the decision makers in the EIB, the EBRD and the World Bank to read the attached EU Report and to:
- Block any future financial support for small hydropower in the Balkans, whether "sustainable" or not, immediately regardless of its location - both in protected areas such as Natura, Emerald, Ramsar..., and/or in not protected areas, block it everywhere.
- Strictly follow the recommendation for "identifying and addressing any significant regional or basin-level environmental and social impacts, in compliance with the Water Framework Directive"
Note:
Here we really hope that the EBRD has not forgotten our case with the Sreden Iskar Cascade in Bulgaria. The problem has been identified alright, now it needs to be properly addressed in the light of the EU WFD! And, of course, someone has to bear responsibility, starting with the notorious EIA/AA experts - Nikolaeva and Pehlivanov! The same goes for the Blagoevgradska Bistritsa Cascade in Bulgaria.
Especially for the World Bank - apart from the need of addressing the existing hydropower pressure in Bulgaria /which is really devastating/, it is quite obvious now that a total ban on any future hydropower development must be set in the new RBMPs for all the River Basins in Bulgaria, everywhere in the country. We hope that the WB team will act in accordance with the recommendations laid down in the above Technical Annex, in order to comply with the new EU Policy towards hydropower in the light of the EU WFD objectives.
It should also be taken into consideration that in the new Integrated National Plan "Energy and Climate" recently adopted in Bulgaria, there is not a single KW of new installed hydropower capacity included in the plan, because small hydro is only causing problems to the balancing system in the spring, when no one needs the extra energy produced, and the actual contribution to the grid during the rest of the time is close to Zero, especially during hot summertime and in the cold winter months. And the problem is just the same in the whole Balkan region!
That said, we are also ready for cooperation any time and will be happy to receive your comments and questions.
In the end - how about one big:
Cheer for the International Day of Action for Rivers!
The time for action has come and we all need to act now.
Kind regards
Balkanka Association, Sofia, Bulgaria
