Independent experts continue presenting their opinions on the EIA of Amulsar gold mining project and the construction of a heap leach facility. www.aarhus.am website has published Seyran Minasyan’s opinion, which says, “The studies of project documentation snow that both the project and the EIA have some drawbacks and gaps. Some environmental impact effects are not taken into consideration in Amulsar mining project and EIA, which have been detected in the open pit mining of similar mines in Armenia.
The first drawback is connected with the underestimation of probable pollution of river basin ecosystems with the dust disseminated from the mine. The problem is as follows: dust dissemination radius in Amulsar open pit mining EIA has been estimated and assessed up to 1 km, while the SIA plans to construct special hydrotechnical structures to prevent dust dissemination through melt water. Nevertheless, the dissemination of wastes, barren rock and mine dust takes places as a result of numerous and different processes (erosion, washing and dissemination with melt water and rainwater, through storms, winds, floods, avalanches etc.). For this reason, the dissemination and spread of dust from mines take place in larger radius than that of the estimated one, as Armenian mining practice shows, where river basins adjacent to mines are polluted with dust in larger distances. For example, the estuary of Masrik River located in a distance of 30 km from Sotq open mine, the bottom substrate of the river is already polluted with the dust emitted from the mine. ”
Amulsar mining project (see Chapter 188.8.131.52 - Management of Surface Water, Erosion Control, Landscape Planning and Recovery, plan measures to prevent dust dissemination and river basin pollution, nevertheless, there are no guarantees that the dust spread from the mine won’t appear in the bottom residues of Arpa, Darb, Vorotan rivers and their brooklets causing relevant impact effects.)
Amulsar mining EIA misses information about the morphological and chemical studies of bottom substrates and status-quo assessments. The EIA also misses the effects of dust impact on the bottom residues of Arpa, Darb, Vorotan Rivers and their brooklets and on river ecosystems, in general.
Proposal: before the mining, there is need to study the bottom substrates of Arpa, Darb, Vorotan rivers and their brooklets and their chemical composition and to fix their current state, then to perform monitoring of the morphology and chemical composition of bottom substrates during mining and closedown. The inclusion of the monitoring of bottom residues in the general monitoring plan will make it more comprehensive and informative, while enable managing environmental risks and reclaiming process more operatively and effectively.
The second drawback is connected with the probable pollution of wild plants, berries, crops in the adjacent areas with the dust spread from mine and assessment of their consequences. The problem is as follows: the pollution of crops and wild plants used by the population can lead not only to serious environmental and but also to socio-economic consequences for the adjacent communities. Mining will definitely endanger the agriculture and ecosystem services in Saravan, Gndevaz, Kechout, Jermuk and Gorayk communities. It can neutralize expected positive economic perspectives in case of mining.
Armenia already has a precedent: high concentration of heavy metals in the harvest of peach orchards in Ayrum because of the dust dissemination from the tailing dump located in Tchotchkan gorge owned by Akhtala Combine.
Amulsar mining EIA misses studies and assessments of the chemical composition of the crops (most common crops) and wild plants, berries, vegetables and probable impact effects on the quantity and quality of plants.
Proposals: To include all adjacent communities – Saravan, Gndevaz, Kechout, Jermuk and Gorayq in the prject affected community list taking into consideration the potential to reduce negative impact and ecosystem services on crops,
To currently study the chemical composition of chemical composition of the crops (most common crops) and wild plants, berries, vegetables in Saravan, Gndevaz, Kechout, Jermuk and Gorayq and fix their current state before the mining, to carry out monitoring of the chemical composition of selected plant species during mining and closedown.
• The inclusion of the monitoring of chemical composition of crops and plants used by the population in the general monitoring plan will make it more comprehensive and informative, while enable managing environmental risks and reclaiming process more operatively and effectively.
• Crop monitoring will enable to assess the probable reduction of the quantity and quality of crops and underlying damage and to develop recovery or fair compensation schemes.
The third drawback is connected with the environmental impact program: Amulsar EIA misses up-to-date and complex environmental impact monitoring plan. It only says that the plan will be developed in future in line with up-to-date high indicators and monitoring will be carried out under individual components of environment within five years after opening, development and closedown of the mine.
Opinion about Amulsar mining documentation and environmental expertise opinion on EIA issued by Nature Protection Ministry: the positive opinion issued by the Nature Protection Ministry on Amulsar open gold mining project is simply brief and formal paraphrasing of the data and scenarios submitted in the project EIA. As a matter of fact, the competent bodies of Nature Protection Ministry factually didn’t carry out any content expertise of Amulsar open gold mining project and EIA, it has a formal nature. For example, no single monitoring data or conclusion have been verified, though there are alternative monitoring research data and scientific publications are available for Vorotan and Arpa river basins. No forecast data or scenario has been recalculated to verify the reliability of forecast data.
In general, irregardless of the formal nature of the positive environmental expertise opinion issued by Nature Protection Ministry, Amulsar gold mining project and EIA have been drawn up conscientiously.
17:38 March 26, 2015