TAI Response to NGO Letter on Qaraberd Gold Mining Expansion Project

TAI Response to NGO Letter on Qaraberd Gold Mining Expansion Project

On November 21, 2022, Hovhannes Harutyunyan, Deputy Minister of Territorial Administration and Infrastructures, responded with his letter N/HH/31532-2022 to the letter regarding the plan to build an ore-dressing plant filed by "EcoLur" and "Center for Community Mobilization and Support" NGOs to expand mining in Qaraberd gold mine located in Qaraberd settlement of Pambak consolidated community in Lori Region.

The reply letter of the Deputy Minister says:

"We would inform you that RA Ministry of Energy and Mineral Resources of has not received an appropriate application regarding the amendment of the project in order to expand mining and build an ore-dressing plant in Qaraberd gold mine located in Qaraberd settlement of Pambak consolidated community in Lori Region, and RA Ministry of Energy and Mineral Resources does not have the authority defined by the legislation to restrict the process of holding public hearings by the soil manager.

Reminder: on 14 November, 2022, “EcoLur” Informational NGO and “Centre for Cummunity Mobilization and Support” NGO addressed a letter to RA Minister of Territorial Administration and Infrastructures Gnel Sanosyan, RA Environment Minister Hakob Simidyan and Head of Pambak consolidated community in Lori Region Suren Kostandyan.

The letter says: “ASSAT” LLC announced public hearings on the gold mining expansion project on November 4 in Pambak, however, local residents opposed and did not allow the hearings, drawing up the appropriate minutes.

“ASSAT” LLC intends to expand gold mining in Qaraberd gold mine and build a mining and processing plant. The company assures that it intends to use new technologies, taking Chinese technologies for the enrichment of raw materials as a basis. “ASSAT” LLC has been operating Qaraberd gold mine since 2012 with breaks. At the same time, the company does not carry out measures for the rehabilitation of territories. Dust from destroyed areas pollutes crops, pastures and meadows, which causes economic and environmental damage to local residents, who are mainly engaged in animal husbandry, beekeeping and other agricultural activities.

The social and economic situation in Qaraberd village, which is under the direct impact of mining, is difficult. The building of the local administration is located in the car, there are no means of communication. There is no school, no kindergarten, no first-aid post in the village, there is no irrigation system.

The expansion of the mining area may adversely affect the implementation of a large environmental project in Pambak consolidated community, which includes Qaraberd village. This project also aims to conserve biodiversity in wildlife migration corridors and supports the transition to a green economy of impacted communities. Parallel activities by extractive companies may lead to the termination of investment in impacted communities. More modest goals are set by individual entrepreneurs who are exploring opportunities for the development of agricultural tourism and other types of tourism in an exceptionally attractive natural area.

All these projects will be jeopardized if the obligations of soil managers to the community - the rehabilitation of disturbed territories, the reduction of environmental pollution based on real indicators and monitoring data, remain on paper. It should be reminded that in 2018, RA Ministry of Energy, Infrastructures and Natural Resources Armenia initiated an administrative case against “ASSAT” LLC for debts. In 2019, the proceedings in the case were terminated after the payment of debts. However, the socio-ecological situation in the community has not changed.

Consideration of the new application filed by “ASSAT” LLC for the expansion of the gold mining area and the construction of a mining and processing plant should be postponed until the revision of the company's obligations for social and economic development in the soil management agreement, and fixing the obligations arising from the real needs of the community, and also until the company will not rehabilitate part of the worked-out areas of Qaraberd gold mine, will not create and provide a fund for all of the above activities, and will not present best practices for the use of mining and processing technologies.

We consider it unacceptable to attempt to hold public hearings only Pambak community, without the participation of Vanadzor Town and Meghrut village, which are under the direct impact of Qaraberd field, but have not received the status of an impacted community.

We call on the local authorities of Pambak consolidated community to initiate special discussions regarding the obligations undertaken, but not fulfilled by “ASSAT” LLC, to demand an assessment of the already existing negative impact of Qaraberd gold mine on the environment, agriculture and the health of the community residents.

With broad citizen participation, the needs and opportunities of the Pambak community and development priorities shall be identified to create a social and environmental policy that will contribute to the sustainable development of the community.

“EcoLur” Informational NGO

“Centre for Cummunity Mobilization and Support” NGO".

November 22, 2022 at 15:22