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"Law Concerning Lake Sevan" and "Overall and Annual Plans for Lake Sevan"

Armenian News Network / Groong
January 7, 2003

by The Greens Union of Armenia
Translated and Edited by Anne Shirinian-Orlando

[Note: All data in this document is official government data obtained
from various ministries. ]


Lake Sevan, located in the Caucasus region and in the extreme
northeast of the Armenian Plateau, is one of the largest high altitude
freshwater lakes in the world. The lake is surrounded by high volcanic
mountains, which rise to over 3,500 meters above sea level.  About
thirty rivers and streams flow into the lake and only one river,
Hrazdan, flows out through a gorge, falling down by 1,000 meters from
the level of the lake. Since the intensive exploitation of Hrazdan
River began, the level of the lake drastically dropped (by about 19
meters), and the lake eutrophied.  Eventually, many hydroelectric
power stations were built on Hrazdan, collectively known as the
Sevan-Hrazdan cascade, which were routing the water for irrigation
down to the fields in the valley, while producing electricity during
the irrigation season. The drop in the lake's water level necessitated
building the Arpa-Sevan 48 Km tunnel, which, after many years of
construction through the mountains, began supplying water to the lake,
in 1981, from part of the Arpa river.  Another tunnel, Vorotan, has
been built in recent years, to supply water to Lake Sevan.  Vorotan is
expected to begin operation very soon.  The Arpa-Sevan tunnel needs
rehabilitation - it is loosing water to the surrounding earth.


In the year 2001, the National Assembly of Armenia (the Parliament)
passed the "Law of Lake Sevan" (Law).  Much effort had been spent in
formulating this law: many working groups of specialists and managers
and various commissions, such as the Commission on Health, the
Commission on Social Issues, the Commission on Nature Conservancy,
etc., collaborated to design the Law.  Afterwards, the Law was
presented to the public as an exemplary sample of environmental
legislation, one that will eventually solve the problems of Lake
Sevan.  Unfortunately, this is not true.  The Law not only will not
solve the problems of Lake Sevan, it will in fact exacerbate the
lake's environmental problems.  Below, discussions and comments are
offered on certain articles of the Law proving that, indeed, the Law
needs a thorough review and rewriting.  We are hoping that the Law
will be re-examined in its entirety since we have chosen only segments
for analysis and discussion.


In the many articles of the Law (in particular, Article #1),
scientific terms and expressions are repeated, sometimes are
inaccurate, poorly defined or not defined, and usage is sloppy with
mistakes.  There is an abundance of vague expressions (which are
typically used in loan or grant based program documents), such as
assessments, regulations, improvement, planning, structuring,
restructuring, development, etc., which, being highly unspecific,
create favorable conditions for corruption.

For example, the first paragraph of Article #29 reads: "In the
immediate zone of influence, the following are being realized:

    a) complete assessment of conditions of landscapes and improvement
of landscape structures.

    b) defining regulations for the planning, programming and
financing of activities for the restoration and for the preservation
of landscapes.

    c) defining and regulating the allowable limits of environmental
stresses resulting from economic, recreational, tourism and health
related activities.

    d) defining the overall requirements of development policy for
town construction, architecture, transportation substructures, as well
as regulating and overseeing design and construction work.

    e) regulation of road use for roads that are currently in use and
for new roads that are being constructed.

    f) inventory of natural and historic monuments, defining
regulations of their use for the purpose of restoring and preserving

    g) any activity which aids the phenomena of flooding and

In particular, note the use of the word "aids" in (g).
This word must be replaced with the word "prevents".  Due to lack of
funds, flood and landslide mitigation efforts have completely ceased
in spite of the fact that they cause great economic damage as well as
pollute the lake.

Certain statements are abstract and unrealistic.  For example, Article
#10 states: "Any type of activity, which is damaging to the
environment of Lake Sevan is forbidden in the central, immediate and
not-immediate zones of influence."  Unfortunately, the definitions of
"central", "immediate" and "not-immediate" zones are found scattered
in other articles.  But the main problem is that the above statement
in Article #10 requires that all industrial, agricultural activities
and transportation cease, since all these activities of the 270,000
people inhabiting the watershed basin of the lake are damaging
activities.  Furthermore, the Law also forbids damaging activities
outside of the immediate physical zone of the lake's watershed basin.
These activities may include, for example, the emissions of the
thermoelectric power plant of the town of Hrazdan, which can easily
reach and pollute the water of Lake Sevan, or, chemical industrial
activities in Ararat Valley, etc.  In addition, one must remember that
the lake's watershed basin is densely populated and crisscrossed with
roads.  Thus, the Law's super-strict requirements are irrelevant.


At the same time, in Article #10, one encounters statements and
loopholes contrary to the strict uncompromising requirements regarding
prevention of all activity damaging to the environment of Lake Sevan.
For example, one reads: "In the zone of immediate influence, the
following are illegal:

    a) emissions, which are exceeding the allowable limits, and use of
wastewater producing technologies...

    d) production of thermal energy based on coal and liquid fuel,
where the energy producing plant will produce greater than 10 Megawatt
of power, is forbidden."

It is worth mentioning that emissions exceeding the legal norms, as
well as wastewater producing technologies are already illegal
throughout Armenia.  Regarding part d), it is a loophole, because one
can have hundreds of coal and liquid fuel based energy producing units
in the watershed basin, each one with a power production capacity of
slightly less than 10 MW.  Furthermore, the wording of d) implies
that, in the lake's watershed basin, thermal energy producing units
based on other sources, such as natural gas, wood, organic wastes,
etc., are allowed with NO restrictions on their power production
capacities.  Thus, part d) almost prompts entrepreneurs to build such
energy producing units.  Also, there is a lack of specifications of
allowable limits on emissions.

In Article #4, there is a statement regarding the ownership of the
coastal transition zones (stretching as far as 150 meters in width, in
some places).  It is stated that these transition belts around Lake
Sevan are the inalienable properties of the government.  Here, one may
ask the question, "Whose property is the remaining territory of Lake
Sevan National Park that lies beyond the 150 meters and stretches
outward several kilometers from the lake, in some spots?"  Similarly,
there is no statement concerning the ownership of the roads, the
mountain slopes, the inhabited land, all within the watershed basin of
Lake Sevan.  This may not be an accident.  In the year 2000, Sevan
National Park (SNP) acquired the status of a government owned closed
shareholding company, and in 2001, another status was given to the
park - a non-commercial organization.  It seems that SNP is gradually
being expelled from the government's budget of financial

Is a Separate Law on Lake Sevan Needed?
What is the Role of the Lake Sevan Commission?

Discussions on creating a separate law for Lake Sevan began in
1994-95, when there was talk about receiving a World Bank (WB) grant
for the realization of a plan for Lake Sevan.  Eventually, WB provided
the funding and, during the years of 1996-98, the "Lake Sevan Action
Program for the Restoration of the Ecological Balance of the Lake"
(LSAP) was created.  Since then, LSAP has become "The Constitution"
for creating all legislation and regulation in the field of
environmental protection of Lake Sevan and its watershed basin.  Now,
in LSAP, on page 26, it was suggested that in order to end all
legislative contradictions and dissentions regarding Lake Sevan, all
laws concerning the problems of the lake and its basin be
"consolidated" into a one single piece of separate law, which
delegates the entire task of restoration and preservation of Lake
Sevan and its watershed basin to the Lake Sevan Commission. LSAP also
promised 300,000 US dollars for the preparation, as well as for the
approval, of a law on Lake Sevan, which will include implementation
mechanisms, and, another 100,000 US dollars for the strengthening of
the law, enforcement and oversight.

First of all, it is enormously challenging to include all the laws
affecting Lake Sevan's condition in a "single law".  And, if created,
such a law must indeed serve the function of dissolving all the
contradictions and confusion regarding all the previous legislation
concerning the welfare of Lake Sevan and its basin.  However, the new
Law has failed in this respect by creating new contradictions.  For
example, legislation of the Republic of Armenia delegates the task of
final and conclusive environmental assessments to the Ministry of
Nature Protection (MONP).  Now, according to the Law, there is a new
additional body - The Commission on Lake Sevan, which, in parallel to
MONP, is responsible for these tasks for the territory covering the
lake and its watershed basin (and possibly beyond the immediate zone
of influence).

As Article #20 states, all the following tasks are delegated to the
Commission on Lake Sevan - preliminary and final environmental
assessments, development of recommendations and conclusions based on
these assessments, gathering data and conducting research, and,
developing the "Overall and Annual Plans" for Lake Sevan and its
basin.  How can the same body (the Commission) be allowed to perform
all the mentioned tasks - the research, all environmental assessments,
development of plans and reporting?  Obviously, this set-up is
contrary to the intent of improving the lake's condition.  It is worth
mentioning that Article #19 determines that the Commission be created
within the structure of the National Academy of Sciences and that all
the operational expenses including the salaries of the members of the
Commission be covered by the government.

Thus, the Commission, as created by the Law (as the Law was created by
LSAP), quickly developed and presented to the National Assembly the
"Overall and Annual Plans" for Lake Sevan and its basin, based on
conducted research, assessments and data gathering.  The National
Assembly quickly approved the presented plans and passed them into law
- The Law on Approval of Overall and Annual Plans of Restoration,
Preservation, Reproduction and Usage of Ecosystems of Lake Sevan - on
December 14, 2001.  Thus, the "Overall and Annual Plans" determine the
future of Lake Sevan and its basin.  As stated by Article #12 of the
Law, "Government policy regarding the restoration, preservation,
reproduction and usage of the ecosystems of Lake Sevan will be carried
out according to the timetables and rules defined in the Overall Plan
on Lake Sevan".  Let us examine the "Overall and Annual Plans" and see
what future is being offered to Lake Sevan.


Here too, just as in the Law, terminology usage is sloppy, sometimes
with mistakes.  However, one of the main problems with this plan lies
in the section "Report on Lake Sevan's and its Watershed Basin's Water
Reserves, Plant and Animal World, Ecological Subsystems" (Report).  In
this section, Lake Sevan's year 2000 water balance is presented and
affirmed without any scientific basis. For example, the following is

Input into Lake (million cubic meters)  Output from Lake (million cubic meters)
Rivers, streams        less than 740.5  Hrazdan River     190.0
Arpa-Sevan Tunnel      less than 311.1  Evaporation      1370.9
Precipitation on lake            388.0  Loss to Aquifer    14.4
Groundwater flow                  94.2
                                 -----                   ------
Total                           1533.8  Total            1575.3

First of all, missing is the fact that annually, in recent years, 120
to 130 million cubic meters of water is directly pumped out of the
lake for industrial and municipal usage of the surrounding towns.
More importantly, the number for loss due to evaporation (1370.9) is
suspect.  Within the period of 1927 to 2001, based on measurements,
the average annual evaporation from the lake has been calculated to be
1055 million cubic meters.  In 2000, the evaporation exceeded the
average number of 1055 million cubic meters by 316 million cubic
meters, or by 30%. This, according to the Report, is a result of
global warming.  The Report claims that this super-evaporation is a
result of a "temperature rise of 0.70C during the last decade,
while during the same period, the precipitation has dropped by 6%."
(Supposedly, the volumes of water flows, precipitation and air
temperature have all been accurately measured.  The Report predicts
increases of evaporation for Lake Sevan in the coming years as a
result of climate change.  Now, an earlier study (financed by
international grant money) had produced a report titled "Armenia -
Climate Change in the Country".  This report displays a map predicting
the conversion of Lake Sevan into two smaller lakes separated by 15
km, with one of the lakes having turned into a swamp.  Another
publication resulting from the same study titled "Questions of Climate
Change", Yerevan, 1999, has predicted the following (see pages
153-167): " the event of 10C temperature rise, the average
annual evaporation from the surface of Lake Sevan will increase by
about 70 mm, or, by 8.3%, for a 20C temperature rise - 116mm, or,
13.5%".  Thus, one can clearly conclude that even with a 0.70C
temperature rise, it is impossible to get a 30% increase in
evaporation.  Thus, through the Report, the Plan offers a very bleak
future for Lake Sevan, since the evaporation from the lake will be
increasing drastically each year.  (This approach is also evident in
academician G. Avakyan's book "Save Sevan", 1999, where he states that
bringing water into Lake Sevan through tunnels, such as Vorotan or
Arpa-Sevan, is not an effective operation, because almost all the
water flowing from the tunnels into the lake will be evaporated - 240
million cubic meters out of 250 million cubic meters for Arpa-Sevan
Tunnel, and 158 million cubic meters out of 165 million cubic meters
for Vorotan Tunnel.  In general, G. Avakyan finds all efforts to raise
the level of the lake unproductive because of large evaporation
increases associated with a larger lake surface.  Actually, previous
measurements show that with a larger volume of water body, the lake's
water temperature changes, such that the surface temperature becomes
cooler - hence, LESS evaporation.)

A closer examination reveals that the water is "missing" and not
evaporated (see Facts section, below).

Another major problem with the Plan is the following.  In the section
titled "Monitoring and Oversight", the "Overall and Annual Plans"
define the following: "The Ministry of Nature Protection, as a
government sanctioned body in the sphere of nature protection, will be
responsible for the Plan's implementation.  The monitoring of the
Plan's implementation will also be assigned to the Ministry of Nature
Protection.  The Plan's independent assessments, as well as all the
professional studies/assessments will be carried out by the Commission
on Lake Sevan's Preservation.  The oversight on the implementation of
"Overall and Annual Plans" will be carried out by the National
Assembly."  (see page 14 of Plan).

Obviously, there is a conflict of interest: the Ministry of Nature
Protection is responsible both for the implementation of the Plan and
for the monitoring of the implementation.  In addition, redundantly,
another oversight is assigned to the National Assembly, which does not
have mechanisms or any means to conduct monitoring checks on the
implementation of the Plan.  However, it is suggested that all the
Plan's activities, such as creation of projects, implementation of
projects, etc., be reported to the National Assembly (Parliament).
Also, it is recommended that independent environmental assessments be
carried out by a body other than the Commission, which is strongly
influenced by funding sources.

Yet another problem with the "Annual Plan" is the following.  Out of
the 20 suggested projects only seven have been funded, with 80% of
funding coming from international sources, mainly bank loans.  One
wonders whether these international funding organizations are the
ones determining the future of Lake Sevan... For example, one of the
funded projects is the "restoration" project of Gili Lake (a small
lake near Sevan Lake).  One million dollars has been allocated to this
project without performing any geologic, hydro-geologic investigations
and/or studies of the site.  Yet, this project had been approved in
the "Annual Plan" of 2000!

All our efforts to find out about the 2002 Plan and its implementation
work have failed so far.

In summary, we would like to state that the "Overall and Annual Plans"
lack project justification studies, the projects are vaguely defined
and lack specifications of volume of work, implementation schedules
and objective conclusions based on scientific investigations.


Those who assign the unexplained deficit in the water balance of Lake
Sevan to evaporation must consider the facts proving that it is simply
incorrect.  A piece of evidence is the letter of the Chief Prosecutor
of the Republic of Armenia addressed to the Prime Minister of Armenia
(N5-9/14-00, 17.11.2000).  In this letter, the Chief Prosecutor cites
several instances of illegal water withdrawals, several instances of
invalid readings of the volume of withdrawn water (broken seals -
compromised measuring devices) and disagreement between readings of
the volume of withdrawn water from different recording stations.  He
ends his letter by stating that after examining much evidence,
documentation, tables of energy output versus input water, etc., he
can claim that water flow measuring devices, in general, are in poor
state, left over from the 50s, and thus, unable to perform accurate
readings.  Also, he states that because the readings are faulty,
conditions are created for cheating in the reporting of withdrawn
volumes of water, as well as in the amount of hydro-electricity
produced by the Sevan hydro-electric station utilizing the withdrawn
water from Lake Sevan.

Another piece of evidence is the letter of the Chief of the Department
of Standards of the Armenian government (N1/37-1105, 12.07.2000)
addressed to the Minister of Nature Protection.  Here is an excerpt
from the letter:

	"...concerning the Sevan hydo-electric station, we cannot
	consider it as a measuring junction, because it is not
	equipped with the necessary required construction structures
	and technologic means."

Thus, the above mentioned letters point to the fact that the problems
of Lake Sevan and its basin have become unmanageable under present
conditions, as already explained in the article "The Condition of Lake
Sevan is Unmanageable" (published in "Golos Armenii" newspaper,
08.06.1999).  There are no flow measuring devices functioning in any
of the 28 rivers and streams flowing into the lake.  In addition, no
measurements of water levels are carried out in any of the tributaries,
there are no functioning devices to measure direct precipitation on
the lake, evaporation from the lake, lake water temperature, volume of
water directly pumped out of the lake, as well as out of the
tributaries.  The only river/stream flowing out of Lake Sevan is
Hrazdan River, which has the hydro-electric station built on it.
There are no independent measurements of the volume of water released
from Lake Sevan for the purpose of producing electricity (the release
concurrently provides irrigation water). The only measurements of
water withdrawals from Lake Sevan (via Hrazdan River) are carried out
at the hydro-electric station and are unreliable, approximate at best,
as indicated in the letter of the Chief of the Department of Standards
of Armenia.

Tracing the history of water balance calculations, it is evident that,
before and including the year 1996, the unexplained deficit of water
balance was not being explained by super-evaporation theory - extreme
evaporation resulting from global warming.  For example, for the years
1992, 1993 and 1994, the following volumes of water were claimed to be
released for irrigation - 416.1 million cubic meters, 649.3 million
cubic meters and 570.1 million cubic meters respectively.  Meanwhile,
total average annual withdrawal during the same years (through Hrazdan
River alone) was 1,300 million cubic meters.  This shows that during
those years, large quantities of water were released in wintertime,
purely for the production of hydro-electricity.  In recent years
(1999, 2000, 2001), the official water withdrawal rate for irrigation
had been lowered to 173 million cubic meters annually.  However, in
reality, it is believed to be a much higher rate because of very large
losses of irrigation water in irrigation canals and, also, because of
irrigation methods.  Thus, for example, water withdrawn from Lake
Sevan (through Hrazdan River) irrigates about 25,000 hectares of land
at a rate of about 8,000 cubic meters of water per hectare, instead of
irrigating at a more efficient rate of 5,000 cubic meters of water per
hectare, in the event of small losses.  Thus, irrigation water use is
highly inefficient.

In 1996, the extra water withdrawal of 81 million cubic meters from
Lake Sevan was justified as being required by the Nuclear Power
Station's safe operation (see Prime Minister A. Sargsyan's 1996
decision -Dec. 30, N691, allowing an extra withdrawal of up to 30
million cubic meters).  Then, in 1997, Prime Minister R. Kocharian
signed on a decision (Nov. 18, N513) to allow an extra withdrawal of
45 million cubic meters, in addition to all the planned withdrawals.
In 1998, the next Prime Minister, A. Darpinian, signed on a decision
(Dec 25, N893) allowing extra withdrawals using the following excuse -
"the need to have a continuous operation of the Sevan hydro-electric
station in order to secure the safe operation of the energy producing

In summary, it is obvious that the volume of water released from Lake
Sevan must be carefully measured and accounted for.  Extra withdrawals
cannot simply be allocated to irrigation, or to the continuous
operation of the Sevan hydro-electric station (which, by the way, has
always used a small volume of water in wintertime for its safe
operation), or, to the safety of Nuclear Power Station, or, finally to


"The Law Concerning Lake Sevan" and the "Overall and Annual Plans" are
faulty pieces of legislation, and are not only misleading documents,
but are seriously damaging to all efforts of managing the problems of
Lake Sevan and its watershed basin.


- "The Law Concerning Lake Sevan" and "Overall and Annual Plans"
need to be re-examined and revised.  (Perhaps this process may
discourage future attempts of creating legislation specific to an

- Certain points need to be added to the Law, such as limiting the
number of boats on the lake, and, also, forbidding privatization of
Vorotan Tunnel, since privatizing this tunnel may interfere with
transporting the water into Lake Sevan.

- Government officials, as well as professionals, responsible for
ill conceived policies and faulty operations/projects must be held
accountable for their mistakes.

- Put a stop to international funding and technical assistance
aimed at changing our laws, and/or creating new laws, for the moment,
until more urgent problems are addressed.

- Use the funding to install measurement and monitoring devices.
It is completely unknown, for example, how much water is being
directly pumped out of Lake Sevan and its tributaries, how much is
being withdrawn from Lake Sevan via the Hrazdan River for the
operation of the energy producing hydro-electric station, as well as
for the purpose of irrigation.

The Greens Union is an officially registered environmental (non-profit)
non-governmental organization (NGO).  Its main goals are -preservation
of nature and of natural resources, prevention of ecological and
environmental disasters and promotion of non-polluting sustainable
technologies (such as solar energy).

The Greens Union of Armenia
Contact:  Dr. Hakob Sanasarian, 
President of The Greens Union
Address:  Mamikoniants St. 47-13, Yerevan, Armenia.
Telephone:  (374-2) 257 -634.
US Contact:  Dr. Anne Shirinian,  phone/fax (732) 462-9089

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