As you know, the mining pirates applied to the ministry for a water use permit from the Arpa River, a section below Kechut Reservoir. We present the objections by AEF, which were sent to the Minister, on the basis of which we consider that this project must be rejected.
The following requirement set forth in Governmental Resolution no. 218-N dated in 2003 is not reliable and has not been fulfilled “Water intake regime by months conditioned with the environmental flow of the water resource to meet the water demand of other water users in that area.”
Kechut Reservoir is built above the presented intake point, on the Arpa River, which plays a regulatory role and completely changes the natural flow of the river and that of the water flow. There are no recent data available on the amount of water released from the reservoir by months since 1994, whereas there are no data available on the months of water shortage since 1989. Without them, it is impossible to make accurate hydrological calculations and get reliable data. With this project, another application for irreversible water intake was submitted from a point where only the environmental flow of the Arpa River exists.
In addition, there are other water users (households, SHPPs, irrigation, fish farming, etc.) above the claimed water intake point, nevertheless, no data is submitted in the project in their regard either.
Under the conditions of the predicted climate change, the river flow in the Arpa basin will decrease by about 4.6% or 31.1 million m3 in 2021 and by 17% or 115.6 million m3 by 2040. There is no hint of this in the project: it is clear that these indicators of projected changes in water supply were not taken calculated and into account when calculating the draft water use permit from the Arpa River for 41.3 l/s.
According to Table 3 presented in the above-mentioned resolution, the water consumption in the industrial sphere in the Arpa River basin will make only 0.08-0.09 million m3 per year in 2019-2021, and according to the project submitted by Lydian Armenia, the annual water demand will make 1.284 million m3. Therefore, the application should be rejected, as it contradicts RA Governmental Reslution no. 338-N dated on March 31, 2016 "On Approving Management Plan of Ararat Basin Area for 2016-2021 and Approving Priority Measures for Effective Management".
It is true that the company claims that it will only draw water, and then the water will be used by the circulating system, eventually it will evaporate, there will be no leakage in other natural aqueducts, but we have grounds not to trust this information.
In addition, the experts of ELARD/TRC confirm that the baseline data in the EIA are mostly incomplete and unreliable, water balance calculations are unreliable, only open pit water systems have been studied, and no studies have been carried out on the heap leach facility (HLF) and its adjacent areas. The fate of the water used and circulating in the HLF for 10 years is not described, it is not known and it is not clear how over 100 million tons of piles accumulated in the HLF will be cleaned afterwards, which will contain extremely dangerous chemicals (sodium cyanide, hydrochloric acid, etc.), dangerous and heavy metals, as well as other highly hazardous chemical compounds resulting from chemical reactions (e.g. thiocyanate).
The project states that it is planned to clean and release them into the Arpa River or one of its tributaries, but does not describe the method of treatment, the design and type of the station, the volumes of water required for that purpose and the quality composition of the discharged water. It should be noted that one of the left tributaries of the Arpa River passes through the central part of HLF, which is not described, its water balance does not exist and the possible impact of the company's activities on that watercourse, and, consequently, on the Arpa River, has not been assessed. All these facts come to prove that there will be discharges into the Arpa River, whereas its exclusion does not correspond to reality.
And last but not least, the vast majority of the current adult population of Jermuk community, including the residents of Jermuk, Kechut, Gndevaz, Her-Her, Karmrashen villages, exercised their right to direct democracy and submitted a collective petition with about 3,000 signatures on December 5, 2019 to the Aldermen’s Council and Jermuk Community Head, where they submitted the vision of economic development of their region, demanded that the metal mining industry be banned in the region and a boost be given to the development of a green eco-economy.
“Armenian Environmental Front” Voluntary Civic Initiative
March 12, 2021 at 17:49