Members of the "Defend the Rivers of Stara Planina" movement are very familiar with the existence and operation of the association called "National Association of Small Hydro Power-Plants", whose president is Dragan Josić. This association doesn't hide the fact that their only goal is to build 850 SHPP in Serbia, as per the 1987 Cadastre (outdated document), although most of these rivers don't even have enough water to run a village watermill.
And since this movement's motto is that the "end justifies the means", they held a meeting in hotel "Moskva" in Belgrade on 13 June 2019. They undoubtedly have right to do so, but they don't have right to distribute inaccurate data through the E-kapija portal.
Their claim that the goal of SHPP is not a destruction of nature, is ridiculous because it's impossible to prove what was their goal and whether they are conscientious or not. If they had wanted to come up with relevant data, they would have analyzed the results of the built SHPP and see that construction has led to catastrophic destruction of mountain rivers and biocenosis in them.
"Dragan Josić, hydro-construction engineer and president of the association, has pointed out that the road to getting the construction permit for SHPP is not simple at all, that it requires obtaining different opinions and permissions - from the information about location, to conceptual solution, to elaborate, to ESIA study, to construction permit at the end. The example of that is building SHPP "Topli Do 1" in Stara Planina, in Pirot municipality. Information about the location was issued by the former Ministry of Construction and Urbanism on 24 July 2013, and the final solution about the construction permit was issued by the Ministry of Construction, Traffic and Infrastructure on 23 August 2017 - said Josić"
This is a serious proof that legal provisions are consciously violated and that water conditions are violated because the pipeline is being buried in the river floodplain and because, in accordance with the enactments of the Article 81 of the Water Law, ZERO liters per second is left to be used by the locals for their private needs.
Furthermore, burying the pipeline in the main river bed violates the conditions of the Environment Protection Institute. In spite of everything mentioned above, and without waiting for the decision of the Environment Protection Institute, public authorities are accepting the project of SHPP "Topli Do 1" and issuing the construction permit. Another interesting fact is that the president of NASHPP especially emphasizes the construction permit for SHPP "Topli Do 1" (he's the planner and investor of the mentioned object) although he's very familiar with the fact that he DID NOT get the needed decision from EPI of Serbia, necessary for issuing the construction permit.
„He clarified that only 62 MW from 100 SHPP has been installed out of the predicted 118 MW. Josić emphasized that the association has reached out to the minister Goran Trivan with the offer for cooperation, and solve the problems with SHPP in Serbia. - We don't run away from the fact that mistakes were made and we say it. We want to fight against all those who don't abide by the laws, regulations and conditions for building and exploitation of the SHPP and we support penalizing them. However, we still haven't received any feedback from the Ministry, although we sent our offer on 21 December 2018, followed by many unsuccessful attempts to schedule a meeting - says Josić."
This part of the statement shows us that the goal of the meeting was to justify the lawlessness and violation of water conditions and conditions of the EPI needed for building SHPP. Their statement that "they fight against all those who disobey the law" sounds very cynical.
If that is the case, then why didn't the NASHPP file a request to reconsider the responsibility of the Ministry of Construction, Traffic and Infrastructure in regards to issuing the construction permit for SHPP "Topli Do 1", which doesn't contain the decision of the EPI?
Yet, it is interesting that the piece of information they mentioned, that 100 SHPP were built in Serbia in 2018, which are operational and produce electricity, is accurate. However, they didn't mention the fact that the owner of three of the SHPP are monasteries of the Serbian Orthodox church and that another three are owned by the Public Enterprise "Elektroprivreda Srbije".
Do Serbian Orthodox Church and EPS happen to be members of the NASHPP?
This time I will mention that 94 SHPP are owned by the private investors. Are all of them members of the aforementioned association?
According to the official data of the Ministry of Mining and Energy, total installed power of these 94 SHPP is 54,271 kW, that is, around 54 MW, meaning that average installed power of one 1 SHPP is 577 kW. This further means that these 94 SHPP have sent (sold) the amount of 186,225,617 kWh, that is, 186.226 MWh to to PE "Elektroprivreda Srbije" in 2018.
If we take into account the transport losses of the PE "EPS" in 2018, which were 12.16% or 3,664,043 MWh, which is almost 20 times more than the total energy redeemed from the members of the NASHPP, it becomes obvious that the claim that SHPP contribute to the energetic stability of the state, are simply nonsense.
However, if all 100 SHPP are taken into account, their total installed power, according to the official MME data is 74,583 kW, that is, around 75 MW.
I wonder why Josić claims that the total installed power is 62 MW?
I believe that they paid special attention to analyzing their profits by destroying 94 rivers. According to the official data of PE "EPS" for 2018, 2,378,623,913 RSD or 20,157,830 EUR has been paid out to the SHPP owners.
There are several "clever" statements in the report from the meeting, which deserve to be mentioned here:
"Professor Dr Svetlana Stevović, research associate of the Innovation Center on the Faculty of Mechanical Engineering for the renewable energy resources, claims that the sustainable development is very important in this period of extensive climate changes. She has pointed out that every kWh of the energy produced in SHPP helps saving 1.6 to 2.2 kg of coal, or 0,25 kg of the crude oil, with a remark that thermal power-plants pollute the environment significantly more."
"Veljko Perić and Dragan Stipčić, members of the Board of Directors of NASHPP and SHPP owners, state that the biggest problem is lack of communication and cooperation with the state, and members of their association are presented as evil-doers. Nobody's talking about the fact that all villagers profit from building SHPP, that production and consumption are on the same place, that CO2 emission of 4-14 g/kWh is by far the smallest comparing to the other plants; that the ones in Jošanička river produce 15 MW of the electricity for Kopaonik, and that not all investors are so conscienceless as presented in public and that they don't deserve to suffer any violence or insults."
Following could be said as a general conclusion:
- The goal of this meeting was to justify illegalities which follow building SHPP, but they were so careless to use SHPP "Topli Do 1" as an example, which is by the way as clear as day example of breaking the laws. One might wonder why they haven't mentioned SHPP "Zvonce" which is even more obvious example of violating the law.
- They tried to defend themselves from the accusations that they pollute the environment using straw man fallacy. Why defending, when nobody accused them of polluting the environment? The fact is, that SHPP don't pollute the nature, but rather destroy the rivers and biocoenosis of the rivers and their banks. Which was, by the way, never mentioned during the mentioned meeting.
Dragan Josić didn't miss the opportunity to tell once again his favorite story how SHPPs are being built all over Switzerland, Norway and Austria and how that's a concept everybody has adopted and supports.
Yet, he didn't mention if there is a designer in any of these countries who would dare to create a project of a construction permit for SHPP without necessary papers from the environment protection institutions, or dare to change water conditions the way he wants, or to design a pipeline inside of a river floodplain.
What would happen to the designers who would do previously mentioned things and sign the statement how project was performed in line with the given conditions and put their stamp on it?
I'm mentioning here the data from the extract from the project for construction permit of SHPP "Topli Do 1", for which they claim it is by the law. Designer of this SHPP is, of course, Dragan Josić.
Is there a designer in Switzerland, Norway or Austria, who would:
- Design a fishway based on the data about the size and types of fish living in the river, but obtains that information by reading a book and observing river from an unknown distance
- Predict in their project to cut all shrubs and bushes in the 5 km radius, and leave the decision how much to cut to the site supervisor and the investor?
Luckily, there is one such designer and investor in Serbia. That is Dragan Josić, investor and designer of the SHPP "Topli Do 1".
However, locals didn't show understanding for such beautiful project and they didn't want several km of their river to be destroyed and its surroundings in a 5 km radius devastated and cleansed from the trees, bushes and shrubs, so they annulled the project of the construction permit.
Locals have annulled this project using the same rights by which the designer has made the project for the construction permit.
I'm not sure that designers and investors in Switzerland, Norway and Austria are capable to build a SHPP like our SHPP "Garine", designed to the perfection by Dragan Josić.
This is indeed one perfect project of the SHPP which guarantees with its 1,300 m long pipeline and perfect fishway, that fish and other protected species won't be wandering around Gobeljski stream like they're used to, but should either obey the new environment or leave Gobeljski potok for good.
There's just one dilemma. Designer who is at the same time a president of NASHPP, keeps emphasizing that Serbia has to build SHPP with total power of 188 MW, and here he missed to use the 8 or 10 MW turbine by mistake, and built some toy turbine of 250 kW.
I don't understand why this big opportunity to increase the total amount of the installed power has been missed.
I would also like to mention that SHPP "Garine" has been issued the exploitation permit on 16 May 2019 and started producing and selling electricity to the PE "EPS" at the privileged price.
Author: Božidar Todorović
Activist of the "Defend the Rivers of Stara Planina (Balkan Mountains)" movement