Inga Zarafyan, EcoLur
Amulsar gold mine development bears huge risks for strategic reserves of water resources, resort zones, biodiversity, historical and cultural heritage of Armenia. These risks are presented in the opinions and expert assessments by competent governmental bodies such as Scientific-expert Committee on Lake Sevan of National Academy of Sciences of Armenia (NAS RA) and Nature Protection Ministry of Armenia. Many scientists, NGOs, independent experts and resort zone representatives expressed their opinions about the project at three conferences held from March to June 2012: 1) impact on Jermuk resort, 2) impact on water resources, 3) impact on biodiversity (see Appendices).
Amulsar project is implemented by Lydian International Limited as represented by its subsidiary “Geoteam” CJSC with its main investors – International Finance Corporation and the European Bank for Reconstruction and Development. On 27 April 2012 EBRD approved financing for Amulsar project with the right to participation in the company’s equity capital . Currently the EBRD financing makes up CAD 5.8 million equity. The project summary document particularly says, “…Lydian is committed to adopting applicable EBRD requirements for environmental, social, health and safety standards."
Examining the information displayed on the websites of Lydian International Company and Geoteam we can see the website displays governmental decision on Amulsar mine development, but it doesn’t display alternative positions and public conferences materials included in the documentation package, which serve as a basis for adopting a governmental decision. The listed below positions reflect and confirm the concerns on the issues raised in the letters , on several occasions and during the EBRD AGM in London 2012, but which did not find the responses from the EBRD.
Jermuk Municipal Council Assessment. The Municipal Council of Jermuk resort town gave its negative assessment to Amulsar project. “Geoteam Company neglected Jermuk resort which has important significance with its healing water and exclusive climatic conditions... Under the government decision “On Declaring Jermuk Town as a Tourism Center” № 1064-N dated on 18.09.2008, Jermuk determined its way to develop and such a mining spot can’t help leaving negative impact on Jermuk’s brand.”
Geoteam Company insists that Jermuk is not within Amulsar project impact area. But Jermuk, if concretely, Kechout village, which is the administrative area of Jermuk resort, was included into the project in 2009 as approved by Nature Protection Ministry of Armenia. Thus, the project affected zone included Jermuk. However, in the expanded project for 2012 Kechout disappeared from the list.
Question to EBRD 1: What are the grounds for removing Kechout-Jermuk from Amulsar project affected zone?
Assessment by Scientific-expert Committee on Lake Sevan Preservation. The Scientific-expert Committee on Lake Sevan Preservation gave its negative assessment to Amulsar open gold mining project. Lake Sevan is a strategic object of freshwater for the Caucasus with its reserves of 35 billion cubic meters. The lake is considered as national wealth and a state priority object protected by RA Law “On Lake Sevan”. The authorities of the Scientific-expert Committee are laid down in Articles 19, 20 and 21 thereof. The official reply of the committee (NЕ/18/2012 ) says (See Appendix 1):
- “The place for tail accumulation at the height of 2570-2360 meters is located in a distance of several kilometers to the epicenter of a disastrous quake in 735. The project doesn’t have any calculations and risk projections for a quake with a magnitude of 10…
- The territory of the tail accumulation has numerous outlets of ground waters, which will spread toxic substances from the tails to the Vorotan River, then through Vorotan-Arpa tunnel to Lake Sevan…
- Explosives may activate landslip processes with their unpredictable consequences….
- The reports of Radman Associates show that radon concentration exceeds the 400 Bq, but the project EIA doesn’t say anything what measures to be undertaken to reduce this level…”
For our part we would like to mention that radon is the first indicator for the presence of radioactive elements in Amulsar ore. Experts Hrachya Avagyan, Chief Specialist at the Institute of Economics of NAS RA, Dr in Geological Sciences, and hydrogeologist Ruben Yadoyan, PhD in Geological Sciences many times voiced this issue in the course the public discussions. G. P. Aloyan’s article entitled “Resource Potential of Radioactive Raw Materials in Armenia and Its Development Perspectives” published in Russian “Mining Journal”, Issue N 6, 2007 proves the same, confirming uranium in Amulsar was estimated to amount up to 76 tons.
Question to EBRD 2: To what extent does Amulsar project concept comply with negative opinion provided by Scientific-expert Committee on Lake Sevan Preservation and what is the proposed list of measures designed for risk reduction?
Opinion of Nature Protection Ministry of Armenia.
Тaking into consideration the requirements of the Ministry of Nature Protection of the Republic of Armenia to the Amulsar project, the ministry had to give a negative opinion, but it gave positive conclusion to the project. Thus, one of the requirements says the project is 'to be guided by requirements of RA Law “On Lake Sevan” for locating a cyanic plant', while the other says, “If any red-listed species are present or detected in the territory designed for mining, the project is to be guided by Article 26 of RA Code “On Subsoil”.” which bans any activity, especially mining on such areas.
The EIA contains data about the presence of red-listed species – Caucasian bear. WWF-Armenia has produced a report on the presence of red-listed flora species on Amulsar’s territory. Moreover, Article 26 of RA Code “On Subsoil” includes cultural and historical heritage sites - in this regard Culture Ministry of Armenia presented the description of monuments in the area, where the company intends to mine.
Article 10 of RA Law “On Lake Sevan” prohibits “any activities exercising harmful impact on Lake Sevan ecosystem” including “ore mining objects”. Geoteam Company intends to place an ore processing plant in the water catchment basin of Lake Sevan. The estimates on mining and extracting fold from Amulsar mine are conducted on the basis of cyanide leaching plant. Annually the company intends to produce 139,856 ounces of gold, 138,248 ounces of silver, and 200 tons of sodium cyanide will be used for this purpose (”Technological Regulations of Heap Leaching Process and Gold Extraction from Amulsar Mine Gold–bearing Quartzite).
Question to EBRD 3: Has the company assessed the technical and financial viability of an alternative technology to heap leaching with cyanide?
Question to EBRD 4: How will the company comply with the requirement of compliance to Article 26 of RA Code “On Subsoil” that bans mining where the red listed biodiversity is detected, as well as cultural and historical heritage sites?
EBRD expects the Environmental and social impact assessment for Amulsar project in summer of 2013, as stated by Alistair Clark, Managing Director, Environment and Sustainability Department in reply to the enquiry of CEE Bankwatch Network. In April 2013 Ex PM Armen Sargsyan was appointed as a director of Lydian International. He served as Special Advisor to the President of the European Bank for Reconstruction and Development (EBRD) and as a Governor of the EBRD from 1999-2000.
Question to EBRD 5: Whether ESIA risks reflected in governmental competent bodies, municipal bodies and public opinion will be included in Amulsar project ESIA.
Question to EBRD 6: Since the EBRD has equity in the company, they have quite strong commercial interest in the project going ahead. So, how objective is EBRD's assessment in this case of conflict of interests.
May 21, 2013 at 14:47