EcoLur
Lydian International Company is seeking to attract shareholders into the development of Amulsar gold mine Armenia. Lydian International Company presented Amulsar project at PDAC-2015 in Canada. The CEO of Lydian International Company Howard Stevenson stated that investments will be attracted and the construction will be launched in 2015, while gold mining will start in 2016. Nevertheless, the company didn’t mention anything about pre-conditioned positive opinion of environmental expertise for Amulsar project and the mandatory requirements of project safety posed by Nature Protection Ministry and naturally not a word about serious risks and threats for strategic water resources, unique biodiversity revealed by public monitoring, as well as nothing about public opposition to Amulsar project.
Below we publish environmental lawyer and ‘Save Teghout’ initiative member Arthur Grigoryan’s article
‘Amulsar Mining Is Illegal and Impermissible
PART ONE
I have joined the group, which opposes to Amulsar mining project considering it, first of all, contradictory to the legislation of the Republic of Armenia, economically harmful and disproportionally risky in viewpoint of ecology and culture.
It should be mentioned that company to be developing Amulsar has presented a quite high-quality EIA, which is not inherent to mining projects implemented in Armenia so far. Nevertheless, nice packaging contains a very vulnerable project in conent and an irresponsible project, the implementation of which is merely illegal.
Amulsar mining can’t be classified as ‘responsible mining’ concept, as it doesn’t comply with ‘performance standards’ it declared and the requirements of the national legislation it prescribes, mentioned by units advocating the mining project - IFC, WB, EBRD, US and UK diplomatc representations etc, thus bearing huge individual responsibility, including for the processes started before the projects...
Another legal issue is that the positive opinion of the environmental expertise of EIA is not an expert document in compliance with the law, but a short summary of the EIA, in my evaluation, which is subject to appellation as an administrative act in all legal ways, including in court.
The heap leach facility is located in the area of Gndevaz community in a distance of 1 km from residential area. The permissibility of the construction of an ore dressing plant and a heap leach facility in such proximity to residential area is also subject to legal assessment, as well as determination of the project affected zone.
- In territorial viewpoint, the most acute legal issue is determining the mining affected zone: taking into consideration that Amulsar is located in the drainage basin of Lake Sevan, while ‘Vorotan-Arpa’ hydrotechnical complex is also an immediate impact zone of Lake Sevan – all the communities located in the drainage basin of Lake Sevan shall also be recognized as Amulsar mining affected communities.
- Spandaryan reservoir is located in a distance of 6 km from mining area (including infrastrucutres), which can store up to 260 million cum water. On the other side, Kechout reservoir is located in a distance of around 4.5 km, from where the accumulated water flows to Lake Sevan through Arpa-Sevan tunnel. Water flows form in the area of Amulsar mine, which supply water to Vorotan, Arpa and Darb rivers, which will be used for different purposes in the area laid down in the EIA, as well as beyond this territory for the irrigation of vineyards for the production of brandy and wine.
- Approximately 22-kilometer-long Spandaryan-Kechout tunnel is located between the mine and the plant, which was constructed to transfer annually around 160 million cum water from Vorotan water accumulated in Spandaryan reservoir to Kechout reservoir, then to Lake Sevan. Some parts of mining affected zones are also Lake Sevan immediate impact zones.
Jermuk resort town is located in a distance of 10 km from Amulsar. Depreciation of Jermuk international fame, probable negative impacts on the vineyards irrigated with the project affected rivers, risks for decrease in wine and brandy production and their quality decrease are subject to alternative economic assessment.
Though the recently passed resolution of the Armenian Government allows to transfer rare and extincting plant species from the mining area, this resolution is subject to appellation in court, as it contradict with RA Code on Subsoil, as well as laws on flora and fauna.
Valuable cultural finds have been detected in Amulsar.
In addition to legal, economic, social, cultural and other contradictory points, Amulsar mining also has a very serous problem, which makes the declared priority of social responsibility impossible: it has already caused a tense intercommunity and intracommunity conflict, which will get deeper and deeper.
March 17, 2015 at 16:00