Problems Detected During "Responsibility of Non-Operating Companies in EITI Process" Project Presented to Romanos Petrosyan

Problems Detected During "Responsibility of Non-Operating Companies in EITI Process" Project Presented to Romanos Petrosyan

At the meeting of the Public Council under RA Environment Minister held on April 30, Victoria Burnazyan, Vice President of “EcoLur” Informational NGO, presented certain results of "Responsibility of Non-Operating Mining Companies in EITI Process" project on mining issues. Those problems are as follows:

About Armanis polymetallic gold mine

“Sagamar” CJSC was to operate Armanis gold-polymetallic mine in Lori Region in 2012-2049. The mine has not been operated since 2015. Acidic waters flow into the Chknagh River. The arable lands of Stepanavan community are polluted with dumps. Mining waste is dumped in Chknagh River gorge. According to RA Environment Ministry reports published on the EITI website for 2016-2018, RA Environment Ministry did not set the basic amount of the monitoring fee for Sagamar CJSC, the company did not pay for that purpose. The basic amount for calculating the environmental protection capital has been set by the ministry at 46500450 AMD. The company did not pay for the replenishment of the fund in 2016-2018, it didn’t pay environmental taxes as well.


To establish a baseline for companies for which no such payment has been set in the past to monitor the area of ​​the extracted mineral, the location of the production dumps generated during extraction, the safety of the population of the surrounding communities, and the health care.

The authorized body may use it to determine the fees during the process of amending soil management agreements (recalculation of reserves, change of coordinates of allocated areas).

To file a motion to Environmental Protection and Mining Inspection Body to carry out complex inspections in the company, to calculate the amount of damage caused to the environment, to recover the calculated amounts in the manner prescribed by law.

About Dastakert tailing dump, dumps and mines developed during Soviet years

Dastakert tailing dump is considered to be conserved, but continues to pollute the environment. The tailing dump is not even included in the document entitled “Information database (report) on abandoned/production dumps without owner and closed facilities generated  as a result of metallic mineral mining” developed by RA Environment Ministry.


Dastakert copper-molybdenum mine, which was developed during the Soviet era, has not been reclaimed, and the mines have not been closed, continuing to pollute the environment.


Find funds for the thorough reclamation of the state-owned Dastakert tailing dump, landfill neutralization, and conservation of mines.

Boghakar Reserve under Pressure

“Litchkvaz” CJSC (new name - AGRS (Armenian Gold Resources Corporation) LLC transports the ore mined in Litchkvaz-Tey gold mine to Kapan Mining and Processing Plant through the territory of Boghakar Reserve in Areviq National Park ignoring the sign banning entrance to the reserve.

Geghanush tailing dump is located in the territory of Geghanush settlement, Syunik Region, its volume is 11 million cubic meters, the area is 45 hectares. Geghanush Tailing Dump EIA received a positive environmental expert opinion for the disposal of industrial waste at the Kapan Mining and Processing Plant. In 2018, "Kapan OPC" CJSC submitted a preliminary application for environmental impact assessment of "Geghanush Tailing Dump Safety and Reliability Increase" project, which was sent back by the Ministry.

According to the project, in case of a seismic impact exceeding 8.5, collapse of the dam is possible in the lower stream of the tailing dump, as well as a leakage of the pulp, which can cover the areas under the dam, including production and other buildings, communication and other infrastructure.

To date, the amount of tails from Litchkvaz-Tey mine on Geghanush tailing dump has not been estimated, which, in its turn, burdens the tailings dump.

Proposal: to evaluate the cumulative effect on the tailing dump, to compel the company to fortify the dam to avoid accidents.

About Terterasar gold mine

Terterasar gold mine development program in Syunik Region is not being implemented, but the Meghri River continues to be polluted by water and dust from the mine area. The tailing dump is not covered yet, rainwater flows into the Meghri River.

Proposal: As Terterasar mining company is not included in the list of companies, to specify the data on the mining company and its owners, clarify their responsibility for the obligations assumed under the soil management contract.

About Tukhmanuk gold mine

Mego Gold LLC, which owned the mining rights to Tukhmanuk gold mine, has not operated since 2015. It is declared bankrupt. The three tailing dumps of the mine have not been reclaimed. In 2016-2018, the company did not make payments to the Environmental Protection Fund for monitoring, did not pay environmental taxes.

Status of Affected Community

Ararat cyanide tailing dump is located in the administrative territory of Ararat Community, Ararat Region. The community is negatively affected by the tailings, but does not have the status of an affected community.


Review the EIAs of all companies, including the communities that have a real negative impact, so that they can use the state subsidies provided by Law on Targeted Use of Environmental Payments by Companies for the implementation of environmental programs.

After the report, Acting Minister Petrosyan asked in an official letter to provide the Ministry of Environment with the results of the study and all the factual data in order to give them further process.

Victoria Burnazyan noted that the results of the project will be summed up soon and will be presented to the ministry.

EcoLur has already sent to the ministry the list of all the companies for which no monitoring fees have been set.

May 04, 2021 at 17:35