Vallex Group Responded to “Alternative Analysis of Teghout Project” Presented by Greens Union of Armenia
Vallex Group responded to the material entitled “Greens Union of Armenia to Represent Teghut Project Alternative Analysis” published on 29.03.2012, which Greens Union of Armenia Chariman Hakob Sanasaryan submitted to EcoLur. Vallex Group letter addressed to EcoLur cites individual extract and lays down comments to 9 provisions of “Alternative Analysis.”
For example, under Sanasaryan, “the company was allotted 1970 ha of land areas, out of which 1589,6 ha is forest and 380,4 ha is community land.” The comment says, “Industrial activities are carried out only in the territory of 914 ha, out of which 408 ha is owned by “Teghout” CJSC, 274 ha is allotted for site development, while 232 ha is leased. That is, the company was allotted 506 ha of land areas, and another 756 ha was assigned to sanitary zone with special legal regime.”
Vallex Group letter says that of “Alternative Analysis” contains inadequate comments and inadequate evaluations in regard with which the company expresses its willingness, if necessary, to give additional clarifications.
Vallex Group and Head of Green Union of Armenia express different opinions about damage caused by development of Teghout deposit
Vallex Group and Head of the Green Union of Armenia Hakob Sanasaryan have expressed different opinions about the damage caused by the development of Teghout deposit.
In late March Sanasaryan published its alternative analysis, according to which the economic damage caused by the deposit development was underestimated for million times.
According to EcoLur NGO, the expert says that the Environmental Impact Assessment (EIA) mentions that the number of trees to be logged is 127,000, while the calculations in the tables of the same document show that there are 170,883 trees present. The logging of 43,883 trees has been concealed, and the economic loss due to such logging has not been presented in either the EIA or the Operational Plan (Plan). In addition, there is no mention in the corresponding table of the EIA of the timber arising from the planned logging of 53333 apple trees (of which 43333 have trunks of 26 cm in diameter).
The economic loss from the mentioned 43333 apple trees is presented as 584.995 million drams, when the calculation using the same coefficient is 866.66 million drams. In other words, the loss has been presented 281.665 million drams less. According to EIA, there are more than 2 million young trees in the areas to be despoiled and destroyed. The economic loss on these alone comes to 9 million drams, which is not reflected in the EIA or the Plan.
At ArmInfo's request, Vallex Group, which is exploiting the deposit, commented on the analysis of the Green Union. Vallex Group said that according to the specified data included in the Plan, a total of 158,610 trees will be cut, and the economic damage is estimated at 1925 mln AMD. As regards the poles, the EIA says that they are in the greater half of the forest territory (375 ha), which is to be deforested for development of the deposit. The company says that the number of poles on 1 ha ranges from 2,000 to 3,000.
Sanasaryan also points out that the damage to the animal world as a result of the violation-destruction-annihilation of the territory by mining and processing has been presented as 175 thousand drams (437 USD). At the same time, Teghout is the inhabitation of animals and birds registered in Red Book of Armenia and in the International Red Book. For its part, Vallex Group stresses that the figure mentioned by Sanasaryan concerns only the economic damage to the fish in the river and Shnogh and its tributaries. Sanasaryan's analysis says that calculations of the cost of damage caused to the economy of the RA have been extremely reduced in the EIA and in the Plan. For example, the cost of 1 square meter of the forest to be allocated to the
tailings dam is calculated at 22.4 drams (0.056 USD). Yet, 17 sq meters of this land has been valued at just 1 dollar.
According to the Plan, 1 sq meter of the area allocated to the open-pit mine is assessed at 2.8 drams (0.007 USD). Thus, the cost of destroying over 143 sq m of forest is only 1 dollar! The area of forest allocated for the construction of the ore processing factory and other structures is valued at 1.2 drams per sq m (0.003 USD), (damage to 333 sq m: 1 dollar).
For its part, Vallex Group says that the damage to the forest in the territory of the tailing dump is estimated at 376245 thsd AMD in the EIA and the Plan, which exceeds Sanasaryan's figures for each hectare. As regards the territory of the open-pit mine, here the damage to the forest is estimated at 828248 thsd AMD. The damage per 1 hectare is 12742277 AMD, and the damage per 1 sq m is 1274.2 AMD.
Sanasaryan also points out legislative shortcomings. "It is beyond doubt that tailings are toxic waste of the highest degree and "empty" rocks are of the second or third degree. According to the RA Law on Tariffs for Environmental Fees, the rate for depositing first-degree toxic waste into the environment is 48000 drams (120dollars) per ton, while that for second degree waste is 24000 drams (60$) and third degree is 4800 drams (12$). Consequently, for depositing 172.8 million tons of tailings in the environment, 8,294 trillion drams must be paid to the state, while for 290 million "empty" rock (even if we consider it third degree toxic waste), 1.392 trillion drams must be paid", Sanasaryan's analysis says.
To note, the program on development of Teghut copper-molybdenum deposit was approved by the Armenian government in November 2007. The hearings focused on issues related to the environmental damage caused by the development of Teghout deposit. In particular, it was pointed out that the development of the deposit will have a negative impact on the animals and birds in Teghout forests. The participants also touched on the consequences of felling of 375 ha of forest for the deposit development. This can lead to reduction of water resources and land resources due to soil erosion.
For their part, the representatives of Vallex Group said that they would use the most advanced technologies so as to prevent negative impacts on the environment. They said that the company was actively planting trees in the area. Instead of 75 ha of cut woods near Teghout, they have planted trees over an area of 200 ha. The company's total investments in the Teghout project exceed 0mln. The Teghout copper and molybdenum deposit is to be launched in 2014.