EcoLur
“Lake Sevan, Gegharkounik Region, Littoral Area 18 representatives have sent a Complaint to EBRD and IFC concerning Amulsar project. The Complaint says, “We, the representatives of the active civil society, live in the communities located on the shores of Lake Sevan, Gegharkounik Region, read the opinion of the environmental expertise of Nature Protection Ministry on Amulsar gold mining published on 28.11.2014.
The opinion says that the project area is a direct impact zone of Lake Sevan (requirement 1: “RA Law “On Lake Seva”, Article 8 says that the zone of direct impact of Lake Sevan basin is an object of special regulation, and when implementing urban development activities the requirements of the governmental resolution N792-N shall be guided with “On Approving Urban Development Procedure in Specially Regulated Objects” and resolution “On Approving Master Plan of Lake Sevan Drainage Basin”, N1787 N dated on 11.12.2003”).
The aforementioned shows that we, the residents of Lake Sevan littoral communities, are also located in the zone of Amulsar project immediate impact. If the requirements of the Nature Protection Ministry are not fulfilled, while the water in Lake Sevan will be polluted with the mining wastes through Arpa-Sevan canal, the residents of over 40 communities will be jeopardized with deprivation of the main source of income – Lake Sevan. Gegharkounik region has very heavy climatic conditions. We have scarce vegetation at over 2000 meters above sea level. We came here and stayed to live here only for the sake of Lake Sevan. Our incomes directly depend on the ecological state of the lake, the pureness of its water, fish reserves, resort activities etc. We are direct stakeholders in the matter of Amulsar project impact. Nevertheless, our rights to the decision-making process on Amulsar project, which are prescribed by the Aarhus Convention and RA Law “On Environmental Impact Assessment and Expertise” were neglected. The Nature Protection Ministry, which determines the list of the communities in the project impact zone, didn’t include our communities in the project affected area. While “Geoteam” CJSC, which is entitled to hold public hearings in the communities undergoing project impact in line with RA Law “On Environmental Impact Assessment and Expertise”, didn’t inform us in proper manner and didn’t organize public hearings in our communities.
We think that our statutory rights are violated both by the company and the government.
The absence of relevant information and neglecting our rights to decision-making process on Amulsar project didn’t enable us, the residents of Lake Sevan littoral area communities, taking part in the discussion of Amulsar project in proper manner.
IFC Performance Standard 1, Assessment and Management of Environmental and Social Risks and Impacts, Clause 8, has been violated, 'Where the project involves specifically identified physical elements, aspects, and facilities that are likely to generate impacts, environmental and social risks and impacts will be identified in the context of the project’s area of influence. The area likely to be affected by: (i) the project and the client’s activities and facilities that are directly owned, operated or managed (including by contractors) and that are a component of the project.'
But our group was not identified when submitting the EIA of Amulsar project, though the matter of impacting Lake Sevan was covered at the public hearings many times.
The provisions of Clause 31 - Informed Consultation and Participation were neglected, 'For projects with potentially significant adverse impacts on Affected Communities, the client will conduct an Informed Consultation and Participation (ICP) process that will build upon the steps outlined above in Consultation and will result in the Affected Communities’ informed participation.'
We would like to advise that no informed consultation was held either at community level or at the level of Gegharkounik regional administration.
Performance Standard 4, Community Health, Safety, and Security, has also been violated – ' The diminution or degradation of natural resources, such as adverse impacts on the quality, quantity, and availability of freshwater, may result in health-related risks and impacts.'
Performance Standard 5, Land Acquisition and Involuntary Resettlement, has also been violated: we would like to advise that nobody hold discussions with the residents of the littoral communities located in the immediate impact zone about involuntary resettlement, in case Lake Sevan is exposed to the threat of pollution.
The same standards have been confirmed in the socio-environmental policy of the EBRD. In addition, we would like to note that the ban on the activities forbidden by the legislation of the project-implementing country or the international conventions on the protection of biodiversity and cultural heritage has also been violated. The violation is as follows: Lake Sevan is inhabited with endemic trout species, which are protected by RA Law 'On Lake Sevan' and the activities will result in the change of the chemical composition of the water conditioned with the industrial wastes.
The absence of proper information and neglecting of our rights to decision-making participation on Amulsar project didn't enable us, the residents of Lake Sevan littoral communities, to completely participate in the discussion of the Amulsar project.
We think that, under such conditions, the opinion of the environmental expertise must be reviewed and include 40 communities, located on the shores of Lake Sevan, in the immediate project affected zone of Amulsar project and once again hold public hearings in the communities and only afterwards 'Environmental Expertise' SNCO must issue an opinion to Amulsar project.
We think that the violation of our rights doesn't comply with the EBRD and IFC standards and we would like to ask to obligate Lydian International and its representative in Armenia, 'Geoteam' CJSC, to withdraw its project and to include assessment on Lake Sevan impact and its communities located in the immediate project affected zone.
On behalf of active civil society of Gegharkounik Region (list attached) the complaint is lodged by Anahit Gevorgyan, Chairman of 'Women's Council of Martuni Communities”.
December 11, 2014 at 13:16