EcoLur
Environmental Public Alliance has addressed a letter to RA Nature Protection Minister Aram Harutyunyan on the crushing and screening plant in the EIA of “Sotq Open Gold Mine” project submitted by “GeoProMining Gold” Company.
The letter says,
“To Nature Protection Minister Aram Harutyunyan
Comments and Proposals from NGOs in regard with the EIA of “Sotq Gold Mine” project submitted by “GeoProMining Gold” Company in the course of public hearings held in Sotq Village on 30 July.
1. On 30 July public hearings on the EIA of “Sotq Gold Open Mining Project” submitted by Geopromining Gold Company and “Lernametalurgiayi Insitute” SCJC were held in Sotq village. The EIA includes the part of crushing and screening plant, which has already constructed without the presence of projected documents, without the positive opinion of the environmental impact expert assessment and without the consent of the community, which in April 2011 in writing expressed its disagreement with the placement of a crushing and screening plant in the administrative territory of the community, without any permit for land alienation.
2. The crushing and screening plant is a processing production and not ore mining, as “GeoProMining Gold” company asserts, consequently, the placement of any ore processing plant in Sotq contradicts to Article 10 of RA Law “On Lake Sevan”, as it threatens to the ecosystem of Lake Sevan.
3. Because of the crushing and screening plant the amount of crushed barren rock for 2011-2012 has increased, which contain heavy metals and toxic substances such as mercury, vanadium, antimony etc and their amount has significantly increased. These wastes are spread in the administrative territory of Sotq Village, Nagorno Karabagh and along the road.
Taking into account the aforementioned we would like to propose:
- to submit a separate project for the crushing and screening plant, which should undergo all the stages of environmental impact expert assessment,
- It should be noted that issuing either positive or negative opinion on the “crushing and screening plant” from competent governmental body doesn’t arise from law requirement, as the list of actions planned to undergo environmental impact assessment prescribed by Article 4 of RA Law “On Environmental Impact Expert Assessment” doesn’t lay down any provision that the use of this plant is ore mining and processing. In this regard, different specialists have different opinions, some of them find this is a processing plant, the others find it not.
- For this reason, we propose to set up a committee with the participation of specialists from Nature Protection Ministry and research centers, which will give professional substantiation that the use of a crushing and screening plant is ore mining and processing, consequently it must undergo environmental expertise by the force of law. If competent governmental body considers this issue, then based on Article 10 of RA Law “On Lake Sevan” it should definitely issue a negative opinion, that the operation of the plant is banned in the territory, as it will negatively affect on Lake Sevan and its ecosystem.
- To recognize the construction and operation of a crushing and screening plant illegal, as it’s not planned activity, but already an existing activity without any permitting document, which contradicts to RA Law “On Environmental Impact Expert Assessment”, and as a processing plant it contradicts to RA Law “On Lake Sevan”.
- to carry out inspections about the crushing and screening plant, to determine the range of impact of industrial crushed wastes on the drainage basin of Lake Sevan, to draw up an act on violations and to impose sanctions on “GeoProMining Gold” company under this act.
Silva Adamyan, Coordinator of Environmental Public Alliance.”
August 29, 2012 at 13:37