Armenian Environmental Front (AEF) Civic Initiative, The Greens Union of Armenia, EcoLur, ‘Union for Sustainable Human Development’, ‘Jermuk Development Center’, ‘Environmental Academy’ NGOs have addressed an open letter to Armenian PM Karen Karapetyan and Nature Protection Minister Artsvik Minasyan calling for annulling the positive opinion issued to Amulsar gold mine. The letter particularly says, ‘Three well-known expert organizations from Australia, USA and Canada upon our US-based fellow countryman Harout Bronozyan have studied over one dozen documents available on the website of Lydian International Company and have presented their assessment and conclusions of a number of ecological risks in Amulsar gold project, which you can find here (https://goo.gl/SuprxD). These risks particularly relate to the potential of acid rock drainage (ARD) potential and effects on surface water and groundwater, assessment of hydro-geo-chemical problems, as well as cleaning of water subject to contamination.
These documents lay down scientifically-grounded omissions, drawbacks available in Lydian’s documents, risk assessments and management plans, as well as case studies of applying unacceptable methods for international standards, insufficient number of researched samples, wrong conclusions and assumptions, completely not assessed or reduced risks, absence of company’s responsibility mechanisms or other extremely serious problems. It turns out Lydian still need to carry out around three dozens of tasks and examinations, out of which some are too wide-scale, too costly and long-term.
The independent experts have come to the following unanimous conclusion:
'Amulsar Mining can't be launched unless all the outstanding environmental problems are properly studied by independent bodies/advisors. The omissions they have detected shall be introduced into acidic and metal-containing drainage management plan, which will be included into the responsibilities and obligations of both the government and the company.'
We have also examined the reports of the independent experts and got convinced that the facts presented in them are scientifically substantiated and can thoroughly serve as a legal basis for the suspension of Amulsar gold mining project.
Without having any relevant experience and professional capacities the Armenian Government, as a matter of fact, hasn't carried out its own serious professional assessment but believed in the assumptions laid down in the documents submitted by Lydian ignoring all other objections and the substantiations of independent experts.
We are calling for Armenian PM to assign RA Nature Protection Ministry, so as the latter thoroughly examines and assesses the aforementioned documents submitted by the international experts, as they clearly mentioned that the expenses for the neutralization of the mining-polluted water can exceed the taxes to be paid to the budget of the state or be completely vested on the state and citizens of Armenia in unpredictable cases. The examinations carried out by the international organizations contain numerous irrefutable facts, which seriously undermine the completeness, reliability, quality and up-to-date state of the information submitted by Lydian.
It should be clearly realized that Amulsar should be paid special attention due to its unique geographical location and enormous volumes of the activities and all kinds of hazards should be professionally substantiated and modeled.
Otherwise, Jermuk mineral waters (see here https://goo.gl/s84hmL), Vorotan, Arpa, Darb River basins, Kechout and Spandaryan reservoirs and the aqueduct tunnels joining them, and, eventually Lake Sevan will be seriously jeopardized.
Besides, it should be taken into consideration that most areas of Amulsar mine are located in the immediate impact zone of Lake Sevan, where any activity can directly or indirectly affect Lake Sevan and the hydrophysical, hydrochemical, hydrobiological, sanitary-toxic, hygienic and other quantitative and qualitative indicators of the water flowing into Lake Sevan (Article 8 of RA Law on Lake Sevan). These examinations prove these negative impacts are inevitable and are not fully assessed by Lydian.
The results of the aforementioned examinations by international experts are, as a matter of fact, new ecological factors, which have emerged after the expert assessment of the amended ESIA of Amulsar gold mining project and issuing a positive opinion to it.
Therefore, we are proposing the RA Nature Protection Ministry to annul the positive opinion EIA 35 issued to this project by the ex Minister in line with Article 21 (2(5)) of RA Law 'On Environmental Impact Assessment and Expertise'.
17:05 August 07, 2017