EcoLur's Open Letter on Alaverdi Copper Smelting Plant and Teghout Project Addressed to Armenian Acting Deputy PM Tigran Avinyan

EcoLur's Open Letter on Alaverdi Copper Smelting Plant and Teghout Project Addressed to Armenian Acting Deputy PM Tigran Avinyan

EcoLur

EcoLur has addressed an open letter to Armenian Acting Deputy PM Tigran Avinyan, the copy has been sent to Head of RA Deputy Staff's Office Serzh Varag Siseryan on Alaverdi Copper Smelting Plant and Teghout project. The letter says:

'Dear Mr. Tigran Avinyan,
It's a fact that the Russian VTB Bank launched 'Property vs Debt' process in September-October in two companies of Vallex Group - 'Teghout' CJSC and 'Armenian Copper Program' CJSC. A meeting was held between you and Vallex Group Company Chair Valeriy Mezhlumyan, during which no certain promise or decision was recorded. It is planned to have another meeting during this week to have more subject-matter discussions. Taking into consideration the circumstance that almost the same problems have arisen also in 'Teghout' CSJC, we are proposing to organize the meeting in a wider format including also the discussion of the matters on 'Teghout' CJSC.

We are proposing to consider the following facts and observations to home more comprehensive, objective and subject-matter discussions, particularly:

- Alaverdi Copper Smelting Plant planned to take a number of environmental measures by October 2017 to reduce emissions of harmful substances into the atmospheric air, particularly that of sulfur dioxide. The schedule of the measures and the temporary volumes of the emissions were approved by RA Nature Protection Minister on 20.03.2013.
With this document, 27979.1 tons per year was recorded only for carbon dioxide as a volume having a disastrous impact on the environment on the condition that, as a result of implementing the aforementioned measures, the amount of polluting substances may reach the limits of permissible norms. Nevertheless, as the inspections of RA Environmental and Mining Inspection showed carried out at the end of September 2018 that the plant didn't carry out any measure aimed at the prevention of the pollution of the atmospheric air, water resources and soil from 2013-2018, except for increasing the smoke chimney by 20 meters. As a result of all this, the aggregate damage caused to the environment, according to the Inspection's estimates, has made up 380 million AMD. Speculating on the tense socio-economic situation, the company applied to the Armenian Government on 11 October in order to receive a permit not to pay imposed fines, as well as to be issued a permit to emit 6 times more than it is laid down in the standards of 2005.
That, they require a permit to issue annually 27979.1 tons of sulfur dioxide, which is equal to annually 42565.84 sulfur acid. That is, during its operation all the processes were organized guided exclusively by economic profit ignoring the conservation of the environment, the health problems of the population in the town and its adjacent areas.

- In January 2018, Director of 'Teghout' CJSC, and later RA Minister for Energy Infrastructures and Natural Resources officially announced that the operation of the enterprise is stopped, as the sustainability criteria of Teghout tailing dump don't comply with the Armenian and international criteria. Among other environmental problems, such as non-prevention of the pollution of atmospheric air, soil, surface water and groundwater, non-performance of the rules on the preservation of the fertile layers of the soil, the fact of the decrease in the sustainability criteria of Teghout tailing dump was recorded. In general, the following violations are available։

1.The absence of the positive expert assessment opinion on the EIA for the second stage of mining operations,

2. Non-performance of the terms of the positive expert assessment opinion on the EIA for the first stage of mining operations,

3. The early fullness of the tailing dump of Teghout ore processing plant,

4. The deterioration of the quality of Shnogh river water in the course of mining operations, the passage from the 2nd (drinking water) category to 5th category (highly polluted),

5. The absence of soil waste management plant laid down in the legislation,

6. The non-implementation of the monitoring aiming to ensure the safety and health of the population in the mined area, in the location of the industrial wastes and adjacent communities,

7. Frequent leaks not complying with water criteria out of the area of Teghout tailing dump, as a result of which a significant part of the cultivated land areas and orchards have been polluted with hazardous substances and compounds and turned out to be not useful for further use.

8. Non-performance of the contractual clause on planting a double surface of forests instead of the felled down forest areas of 223.2 ha in the sections of mining exploration and development. The information presented by the company on the reforestation of 562 ha doesn't comply with the reality.

9. Formation of an extremely sensitive social situation in the region.

Based on the aforementioned, we are proposing:
• The active participation of the Armenian Government in the processes ongoing between the Russian VTB Bank and Vallex Group on Teghout Copper and Molybdenum Mine and Alaverdi Copper Smelting Plant using all the leverages of impact prescribed to the state by the Armenian legislation,
• To organize processes in the format of State-Russian VTB Bank and Vallex Group Company,
• To demand from Vallex Group Company a relevant environmental and social audit in the acceptance process,
• To reject the application of Vallex Group Company on issuing a permit to emit 6 times more than in it as allowed in the permit issued in 2005,
• To demand financial appraisal of defaulted environmental and social obligations by 'Teghout' CJSC and to secure guarantees to ensure these means,
• In case of the potential sale of Teghout Copper and Molybdenum Mine and Alaverdi Copper Smelting Mine, to demand from the Russian VTB Bank an action plan on making the sector healthier setting the certain and reasonable schedule of their implementation.
• To plan the formation of multilateral and sectoral working groups to support the negotiations running on this problem and to receive professional opinions.

14:42 October 20, 2018


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