EcoLur
"Lydian International" company organizes a ceries of public discussions on the document of Amulsar gold project entitled "Environmental and Social Impact Assessment".
On July 23 the discussion took place in Yerevan.
As it is mentioned in the official invitation its main goal is getting funds from the main donors of Amulsar project namely International Financial Corporation (IFC) and European Bank for Reconstruction and Development, which have to meet the Equator principles.
The whole discussion process of "Environmental and Social Impact Assessment" is of imitation nature. The description and assessment of the real risks of Amulsar project are missing in the voluminous documents under discussion. There is no evidence of the risks being managable. First of all it refers to the potential contamination of strategic water resources namely Arpa and Vorotan river basins, Lake Sevan, both Kechut and Spandaryan reservoirs.
Those pronciples are intended to detect, assess and manage the social and environmental risks and impacts so that to prevent the negative impacts on health and environment coming from the projects financed by financial development institutions.
The next issue is the risks for "Jermuk" mineral waters as a result of potential explosions in Amulsar mine in a high seismic zone and the brand loss of Jermuk health resort.
The next issue refers to the risks for the red-listed species living in the whole infrastructure of Amulsar mine. Another risk is the soil contamination which will result in ruduction of agricultural production and ecological migration.
Thus, the environmental legislation violations are completely ignored in the document which have been publicly presented by lawyers and ecologists (links) many times. Let's enumerate the violations article by article.
The following articles have been violated:
- Article 10 of RA Law “On Lake Sevan says: “Any activity in the central, immediate and non-immediate impact zones having harmful impact on Lake Sevan ecosystem is banned.”
- Article 21 of RA Land Code, "Sanitary conservation zones are set in the resort areas, where conducting explosions and any business activities polluting environment are banned".
- Article 99 of RA Water Code, "The water resources in Armenia are subject to conservation and special requirements are set for their conservation".
- Article 108 of RA Water Code bans the location waste burial sites, landfill sites, cemeteries and other objects having indirect harmful impact on the quality of water resources.
- Article 104 of the RA Water Code says that it’s banned to use the resource for wastewater, which contains natural medical resources, which is located in the specially protected drainage basin area, in the proximity of resorts, as well as they are spots for fish spawning, animal or plant habitat. In this case, all these features are available.
- The resolution of the Armenian Government no. 1064-N dated on 18.09.2008 “On Declaring Jermuk Town a Tourism Center”, which says, “4. Jermuk Town, Armenia, rich in resort resources, has its own place and traditions.”
- Article 31 of RA Law “On Preservation of Atmospheric Air” bans the location of mine wastes and dumps in residential areas, storage of other wastes, which are sources of polluting the atmospheric air with dust and harmful substances.
- Article 26 of RA Code on Subsoil bans soil management, if the areas include cemeteries, monuments of nature, history and culture, red-listed species habitat, as well as animal immigration paths.
- 11 Article of the Armenian Constitution, “Monuments of history and culture and other cultural assets are under the care and protection of the state.”
- 17 Article of RA Law “On Fauna” and 16 Article of the same Law on “Flora”, "All the objects of the RA Fauna and Flora are subject to legal protection".
- The 1st Section of Article 5 of RA Law on “Environmental Impact Assessment and Expertise”, "Assessment must at least cover forecasting, description and appraisal of possible direct and indirect impacts of intended activity related to weather conditions, flora and fauna, individual elements of eco-systems, their inter-relations and stability, specially protected natural areas, landscapes, geomorphological structures, air, surface and ground waters, and soils, the health and well-being of the population".
- Article 5 of RA Law on “Environmental Impact Assessment and Expertise” includes basic data on the impact of intended activity on the environment; the degree of possible impact and danger for individual components of the environment.
- 33.2 Article of the Armenian Constitution, “Everyone shall have the right to live in an environment favorable to his/her health and well-being and shall be obliged to protect and improve it in person or jointly with others.”
- Article 10 of the Armenian Constitution, “The state shall ensure the protection and reproduction of the environment and the reasonable utilization of natural resources.”
- 31 Article of the Armenian Constitution, “Everyone shall have the right to freely own, use, dispose of and bequeath the property belonging to him/her. The right to property shall not be exercised to cause damage to the environment or infringe on the rights and lawful interests of other persons, the society and the state.”
The public has many times called for IFC and EBRD financial institutions describing the risks in details, has presented the opinions of independent experts and scientists but it has received an answer that the decision of Amulsar mine operation hasn't been made yet.
In this document entitled "Environmental and Social Impact Assessment" which was made up 6 months later after the conclusion made by "Environmenatl Expertise" SNCO, nothing is written about any of the six requirements having been executed.
We call for the investors to be principal in their social and environmental policy, take into account all the proofs of previously presented unmanagable risks of Amulsar project and bring it to Category A, the most dangerous category level, recognize the serious legislation violations, adopt the economic inability of Amulsar project and refuse the capital shares of Lydian International.
July 24, 2015 at 17:47