EcoLur
To Regional Manager in South Caucasus
Mr.Thomas Lubeck,
To Contact Representative in Armenia
Mrs. Anna Dira,
To Investment Officer
Mr. Arman Barkhudaryan
Letter
IFC together with EBRD is one of the shareholders of British Lydian International Ltd. Owning the right to Amulsar gold mining (10.23% and 6,8% of shares, respectively). Being an international financial institution, IFC declares about the principles of social and environmental responsibility, which we, as public representatives, would like to see implemented in the certain projects supported by IFC. We would like to draw your attention to the fact that the actions on Amulsar project don’t comply with the standards and practices, while both “Geoteam” CJSC (100% owned by Lydian International Ltd) and IBC bear responsibility for its compliance. The domestic legislation and provisions of international environmental conventions ratified by Armenia are also violated.
Environmental Expertise, EIA
The Environmental Impact Assessment has been carried out twice for environment in 2009 and 2012. The assessment is reflected in the official documents archives at Nature Protection Ministry of Armenia. The environmental expertise opinion for 2009 expired in 2010. The second environmental expertise opinion was issued in 2012. The Nature Protection Ministry put forward a number of conditions in its opinion (see the official website of Nature Protection Ministry http://www.mnp.am/?aid=592).
1. One of the requirements say: “To be guided with the requirements of RA Law “On Lake Sevan” in regard with placing a heap leach facility. Lake Sevan is a national and strategic priority in Armenia with its freshwater reserves of 35 billion cubic meters.” The ban on Amulsar project actions is reflected in Article 3 of RA Law “On Lake Sevan”, “Article 3: Kechout and Spandaryan reservoirs are a part of Lake Sevan catchment basin, as well as Arpa and Vorotan river catchment basins up to Kechout reservoir.” “Article 10 (1): Any activities having adverse impact on Lake Sevan ecosystem are banned in the central zone, in zones of direct and indirect impact. Article 10 (2): … Placing facilities for mineral ore processing…”
2. It should be noted that the Armenian Government adopted resolution 749 – N dated on 18 July 2013, which says that Arpa-Sevan Tunnel is a direct impact zone of Sevan catchment basin in a distance of 3000 meters. In line with RA Law “On Lake Sevan” (Article 10) any ore processing facilities are banned to be constructed in the direct impact zone. Thus tunnel runs through the territory of heap leach facility for Amulsar ore processing, i.e. the construction project of a heap leach facility near Gndevaz Village must be reviewed for the second time, as the first time the facility was planned to be constructed in the administrative territory of Gorayk Village. Nevertheless, the territory was replaced because of the ban prescribed by Article 10 of RA Law “On Lake Sevan”. Now the territory of Gndevaz Village is extremely disputable for the construction of a heap leach facility.
3. The Scientific-expert Committee on Lake Sevan Preservation gave its negative assessment to all infrastructures of Amulsar open gold mining project, including mine and waste disposal. 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:
- “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…”
4. Another requirement of the environmental expertise opinion on Amulsar project hasn’t been performed either, “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 (http://www.mnp.am/?aid=592). However, the findings of WWF Armenia studies show that the following red-listed species have been detected in Amulsar and its adjacent areas: one plant species - Potentilla porphyrantha, two species of lizard, eighteen species of birds and four species of mammals – all red-listed in the Red Book of Armenia. The Amulsar Project EIA says, the project territory has only one species inhabiting – Caucasian brown bear.
Hazards for Jermuk resort town: Jermuk is located in a distance of 12 km from Amulsar. Jermuk is rich in hot springs and mineral water. Under the government decision “On Declaring Jermuk Town as a Tourism Center” № 1064-N dated on 18.09.2008 Jermuk was recognized as a tourism center. Under Jermuk Development Plan, the border of tourism zone approaches Amulsar in a distance of 2-4 km. Jermuk is famous for the production of “Jermuk” bottled mineral water, which is also exported. Millions of investments have been made into Jermuk. However, explosions and dust of an open pit mining, water and soil intoxication because of over 90 million tons of tails (70 million tons without overburden) and a heap leach facility will have its adverse affect on Jermuk brand. Besides, brittle mineral springs may get disappeared because of the consequences of explosions. That is, Jermuk has no future.
Geoteam Company insists that Jermuk is not within Amulsar project affected zone. But Jermuk, if to be precise, 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. The paradox is that Kechout disappeared from the list in the expanded project for 2012.
IFC Policy
During the working visit to Amulsar by IFC and EBRD delegation from 4 to7 June 2013, Principal Investment Officer at IFC said, “The IFC chooses its clients, such as Lydian, in the mining industry very carefully. The most important criteria are the company’s commitment to following good environmental and social standards.”
It should be noted that IFC, and after a while EBRD, became the shareholders of Lydian International Ltd., which is categorized as so-called junior company, i.e. with no previous experience in mining. Lydian International Ltd. Was founded in 2005, almost in parallel with the start of gold resource study in Amulsar. And so far Amulsar is the main project in the company portfolio. But even in case of Amulsar the company is not engaged in mine development, but only geological prospecting and investigation. Consequently, it’s a mystery what “careful choice” means in the idea of IFC representatives.
What about following good environmental and social standards, the entire process of EIA and other documentation consideration shows that Amulsar project bears high risks and threats for pollution of strategic water objects, agricultural land areas with heavy metals and elements, poses hazard to the existence of mineral waters recognized as specially protected areas (Jermuk hydrological reserve) and conservation of red-listed species.
We would also like to draw the attention to the fact that the discussion of Amulsar project is gradually transferred to political field, as a series of negotiations of World Bank and EBRD representatives shows, as well as the meeting of the UK Extraordinary and Plenipotentiary Ambassador to Armenia Catherine Leach with Nature Protection Minister Aram Harutyunyan. The protest demonstrations of public activists directed against Prince Wales Charles’s visit to Amulsar also prove it. But Amulsar project is not a political one and doesn’t need political decisions, and Minister Aram Harutyunyan is responsible for nature protection and not investments. If Amulsar project needed political decision, the issuance of permits and opinions should have done not at Nature Protection Ministry, but in other bodies, including political ones.
Taking into consideration the aforementioned we would like to outline that the activities on Amulsar project don’t comply with the following IFC standards: 1. on ensuring environmental and social sustainability, 2. on rational use of resources and prevention of environmental pollution, 3. on health protection and population safety.
We think that IFC, having commitments in standard performance, should suspend its participation it Amulsar project unless these standards are performed.
«EcoLur» NGO Inga Zarafyan
«Jermouk doesn't became a mine» Public Initiative Tehmine Yenoqyan
«Jermouk development Center» NGO Vazgen Galstyan
«Save Teghout» Public initiative Anna Shahnazaryan
«Bird lovers Center» NGO Silva Adamyan
«EcoIravunq» NGO Artur Grigoryan
Sona Ayvazyan, expert on environmental policy
September 06, 2013 at 13:31