Global Independent Analytics
Radostina Schivatcheva
Radostina Schivatcheva

Location: Bulgaria

Specialization: Sustainable development, International relations, Comparative European politics, European integration, Eastern European politics and EU-Russia relations

‘Green’ energy? ‘So long and thanks for all the fish’

The European fish populations are failing. The state of the European rivers is alarming. Hydroelectricity has much to do with these failures.

These conclusions were made by the Recreational Fisheries and Aquatic Environment Forum in the European Parliament, which took place on the 10th of November, 2015. ‘Think like a mountain,’ implored Aldo Leopold, the veritable father of modern land ethic. Today in Europe, as supposedly ‘green’ and ‘sustainable’ micro Hydro Power Plants (HPP) threaten fish habitats, those who are keen to preserve the ichthyofauna need to start ‘thinking like a river’. 
 
But while affluent Brussels slowly recognizes that ‘hydropower energy is not a perfect solution for nature’, let us consider the situation in the poor European periphery focusing on Bulgaria, the poorest EU member-state. Bulgaria is a mountainous country, but its water resources are insignificant - about 20.1 billion m3[i]. The length of flowing water is 20,231 km and the runoff is almost entirely from mountainous areas. The rivers are relatively short, quite shallow, with no major watersheds. All major rivers are heavily polluted. In spite of the ostensibly unfavourable habitat, Bulgaria’s complex biogeographical and geological history has resulted in a rich variety of aquatic organisms, including a significant number of species unique to the Balkan Peninsula. The Bulgarians appreciate their diverse freshwater fauna. In the words of one sport fishing enthusiast: ‘The fish make our hearts beat faster and stronger’ [ii]
 
What is a micro Hydro Power Plant (HPP)?
 
The European Renewable energy directive (2009/28/EC) established and promoted the production of energy from renewable sources in the EU, providing the legal framework for the compulsory purchase of energy from renewable sources at preferential prices. The mandatory transposition of European law to Bulgarian legislation has spurred an excessive investor interest in ‘green’ hydro energy. In Bulgaria the preferential prices are guaranteed by the government for 15 years. Consequently, numerous micro Hydro Power Plants (HPP) have rapidly been constructed in Bulgarian rivers.
 
But what is a micro HPP? A micro HPP produces up to 500 kW energy. For those technically minded: a micro HPP has a barrage and water turbines. The barrage pools the water behind it to allow for a steady water flow towards the turbines. The latter, as they are being turned by the water pressure, produce energy. HPP turbines need a minimum amount of water with a certain pressure in order to turn and produce energy. Yet the slope and shape of the watercourse do not always allow placing the turbines on the river bed. In such cases water is diverted via a bypass from the watercourse to the place, wherein the turbines are located. The bypass provides for the slope and pressure needed to turn the turbines and produce electricity. Then, the water is returned back to the original watercourse, far below the place it was diverted from. However, not all available water should be diverted towards the turbines. Some water also needs to be discharged at an ecological minimum flow (set by the Water Permit) directly through the barrage in order to support life in the river. If the construction does not comply with the legal requirement, the river bed between the water uptake and return is left completely dry and devoid of all forms of aquatic life.
 
Energy production from the power of the waterfall has clear environmental benefits, since it uses ‘clean’ and renewable energy sources. Ideally, this would be the case, as long as the production process complies with the environmental standards and protects life in the rivers and around them. Yet, when economic priorities intertwine with ecological necessities, nature conservation becomes not the goal, but the obstacle to the investors’ appetites.
 
The ‘green energy rush’
 
‘Think like an investor’ - unfortunately for the fish, this slogan has dominated the mindset of the Bulgarian government administration. Meanwhile investors have been keen to channel every droplet hydroelectric potential of the Bulgarian rivers. Statistics show that currently approximately 247 micro HPPs are in operation. Another 250 plants are in different stages of implementation, but they have already been issued Permits for the use of surface water from the River Basins Directorates (RBD). Although the exact number of all future micro HPPs cannot be established with complete certainty, at least another 400 river-points have been issued permits for future development. Thus, even according to the most conservative estimates, at least 900 river-points contain or will contain micro HPPs. In fact, investors’ pressure has been so great and the permits have been issued at such speed that even records of the state agencies are incomplete. For example – the West Aegean RBD alone, responsible for Southwest Bulgaria, has issued 516 permits.
 
Judging by the number of permits issued, Bulgaria’s energy needs are to be completely covered by renewable energy sources. However, a closer look below the surface of this green and energy-plentiful idyll reveals the murky waters underneath. A coalition of Bulgarian NGOs, spearheaded by the local fishing Association Balkanka has recently prepared a complaint to the European Commission (EC), expressing grave concern over the environmental destruction[iii] resulting from the production of ‘green’ energy from the Bulgarian micro HPPs.
 
J’accuse!
 
In a report, addressed to the EC, Balkanka notes that none of the major Bulgarian environmental governance organizations has complied with Community law: most notably the Bulgarian Ministry of the Environment and Waters (MOEW), the Regional Inspectorates of Environment and Waters (RIEW) and the RBDs. The law demands that green energy investors must comply with the following basic requirements:
  • Micro HPP ought to release into the river a mandatory minimum quantity of water in order to ensure the survival of the ecosystems of the river and its basin.
  • Micro HPPs ought to provide opportunity for the migration of fish and other aquatic organisms through appropriate fish passages – in order to ensure their reproduction and survival.
  • The green energy investor ought to collect and clean the accumulated silt sediments from the lake and from behind the dam’s wall and not release these sediments into the river.
 
The law tries to ensure sustainable and sound environmental management. Yet many environmental NGOs have expressed concern since they consider that there are too many clear cases of offences and non-compliance. In the opinion of the NGOs, the government has been ignoring its responsibility to take action against the environmental violators.
 
An inconvenient truth
 
Balkanka’s report presents a documented account of an ‘inconvenient truth’. The NGO’s complaint to the EC enumerates various breaches of law: “Dry river beds, poor fish-pass design and construction; fish passes which are impossible to be passed even by experienced climbers, much less by any fish - this is the actual environmental impact of about 50 (out of some 220) new HPP in Bulgaria, that Balkanka has already visited and taken pictures of... Trying to resolve some of the problems ... we have walked all possible paths, including meetings with the RBD management, with the Minister of MOEW, the Supreme Water Council and the Commission of the Environment and Waters of the Bulgarian Parliament... We have been exposing many documented infringements. They have expressed sympathy, empathy, consent, yet no action has been taken by the state authorities to address the problem”.
 
Dry rivers – this is the result of government inaction. Dry white boulders and rocks cover stretches that are 5-7 km long in the rivers Cherni Vit and Kriva Reka. No form of aquatic life is possible in these ‘gunpowder dry’ river beds. The ‘impassable bush’ is another equally sinister consequence of improper HPP construction and exploitation. Wherein the environmental conditions allow, brushes and trees are quick to colonize the dry river bed. At Zlatna Panega river, the river bed behind the dam has becomes a dense impassable bush. Subsequently, the conductivity of the river channel is reduced significantly, leading to an increase in the flood risk. Furthermore, no water can be pumped out of the dry river bed in order to fight and extinguish forest fires, which are a frequent occurrence in this part of Europe in summer.
 
The fragmentation of the fish population is another particularly damaging impact of improperly built and operated HPPs. As cascades of HPPs are built along the same river, the excessive construction breaks the fish population and precludes genetic exchange between different fish sub-populations. Less genetic diversity means lesser chances for survival and adaptation.
 
The law tries to protect the fish. Under the Bulgarian Fishery and Aquaculture Act, owners of all water abstraction facilities must make design provisions for the migration of fish and other aquatic organisms; these provisions involve the planning and construction of fish passes. Yet, in order to save costs, many fictitious fish passes are built, impassable even by human climbers. An Egyptian pyramid – this is what the hideous fish-pass on Davidkovska river look like. The tall, sharply rising step-wise construction is impossible to be navigated by any fish.
Not only are the artefacts of greedy investors of no help to the ichthyofauna, but the aquatic organisms also have to cope with a legacy of water abstraction facilities, built before the ‘green energy rush’. Despite the legal requirements, too many old facilities have no fish passes at all, no matter if appropriate or not. This maze of old and new installation on the Bulgarian rivers restricts the movement of aquatic organisms, turning long stretches of river into deadlocked zones. Those, who ‘think like a river’ have already started questioning, whether producing a few more Watts of ‘green’ energy is worth risking the health and diversity of Bulgaria’s freshwater fauna.
 
While the profit-feeding frenzy of some ‘green’ investors has been destroying the ichthyofauna, the Leviathan of state power has been notably absent. The RBDs monitor the conductivity of rivers used for HPP two times per calendar year. In the end of each year, the monitoring reports are submitted to the MOEW. In spite of the numerous breaches of law, photos taken by NGOs and civil society, the state apparently monitors with eyes wide shut. Everything is ‘OK on paper’ - in 2014 all RBDs in the country reported that no problems have been discovered, so that ‘human beings and fish can coexist peacefully’.
 
The aftermath of the ‘green energy rush’
 
The Bulgarian ‘minimal’ neoliberal state, the result of 25 years long post-socialist ‘transition’, has proved incapable of protecting the environment and ensuring the sustainable management of micro HPP installations. The lack of adequate legislation and proper monitoring and control has resulted in the deterioration and even outright destruction of aquatic habitats and fish populations. Although things are ‘ok on paper,’ today many of Bulgaria’s protected areas are in danger of becoming paper parks’ only. Meanwhile, the small fish of the Bulgarian rivers, having fallen prey to the big fish from the investors’ pool, are now also in danger of becoming ‘paper fish’ only.
Still, in spite of the formidable challenges, the official NGO complaint to the EC is not only an alarm about the threats to Bulgaria’s aqua fauna, but also an acknowledgement of the organizational civic power of the civil society – the numerous volunteers and enthusiasts, who have collected the evidence about the environmental offences. Hope rests with those who already ‘think like a river,’ those who acknowledge that: “Every stream, every river has its own individuality. Bulgaria has unique rivers, streams and high-mountain lakes. These are the most beautiful places in my country, which will always have a special place in my heart”[iv].
 
 

[i] National Agency for Fishing and Aquaculture, 09.2014, Multiannual national strategic plan for aquacultures in Bulgaria 2014-2020, Sofia, Bulgaria
 
[ii] Fisherman’s comment during a discussion in Sofia, Bulgaria 10.01.2016
 
[iii] Balkanka Association, 29.06.2015, Complaint to the European Commission, concerning failure to comply with community law. Sofia, Bulgaria
 
[iv] Another quote from the discussion with the fisherman in Sofia, Bulgaria 10.01.2016.

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