

This is the fifth time that Lydian Armenia CJSC has applied to Environment Ministry for a water use permit for Amulsar gold-bearing quartzite mining. Three of the previous four applications were for projects to draw water from the Arpa River and one from the Darb River. The company currently has a permit for the use of 11 l/s water from the Arpa River, which it received in 2020. The other three were rejected by Environment Ministry. The company is still disputing the ministry's rejections in RA Administrative Court.
The company submitted its latest application for a new water use permit from the Arpa River a few days ago.
On January 24, 2022, the public discussion on the draft water permit for industrial use (WP) with a volume of 41.3 l/s took place on January 24, 2022, in a rather tense environment.
Civil society representatives were represented by Inga Zarafyan, President of EcoLur Informational NGO, Nazeli Vardanyan, Director of Forests of Armenia NGO, Tehmine Yenoqyan, Director of Green Armenia NGO, and Ani Khachatryan and Arpine Galfayan, members of the Armenian Environmental Front Initiative.
Paruyr Simonyan, Assistant Minister of Agriculture, Ori Avetisyan, Acting Head of Water Resources Management Department, Mariam Lezhunts, Acting Head of Water Use Permits Department, Artak Martirosyan, Senior Specialist of Ararat Basin Territorial Administration Department, Sevak Matilyan, Chief Specialist of Cadastre Management and Monitoring Department, and Head of Legal Department of Ministry Khachatur Khachatryan. Taron Navasardyan, Sayad Badalyan and Arthur Pepanyan from Lydian Armenia Company tok part in the meeting.
At the beginning of the discussion, Nazeli Vardanyan mentioned that both cases on water intake from the Arpa River were being heard in the Administrative Court, and suggested terminating the administrative proceedings on the new application for a water intake permit from the Arpa River.
In this case, the Ministry is not authorized to conduct administrative proceedings, to hold hearings, to discuss the application, as according to Article 50 of RA Law on "Fundamentals of Administration and Administrative Proceedings, “1. The administrative proceedings initiated by the application are terminated if: d) there is a case on the same subject between the same persons on the same grounds in the court proceedings,” the lawyer explained. The representatives of the Ministry took note of Nazeli Vardanyan's proposal, but the proposal to cancel the public discussion was not upheld.
The requirement to submit a draft civil society application was also not met. The request to clarify the difference between the two applications challenged in the Administrative Court and the new application was given an uncertain answer as to whether they were different in terms of water intake point.
Civil society representatives presented the shortcomings and risks of this WP application. In particular, it does not consider the fact that the term of Ararat Valley water basin management plan expired in 2021, whereas the new plan has not been approved yet. The factor of climate change has not been considered - the sharp reduction of water resources, the interests of other water users, and only promises have been made about the risks without justification or facts. The application does not include a drainage system. It was also presented that the company had already polluted the Arpa River during the construction, about which there is an official act.
According to civil society representatives, one of the reasons for the rejection is the corruption risks associated with the illegal sale of land in Gndevaz Village, as well as the fact that Jermuk consolidated Aldermen’s Council reached a decision in 2018 approving the collective petition submitted by the community to Aldermen’s Council on turning Jermuk into an eco-economic area and banning metal mining in the community. In addition, no public hearings were held in Jermuk community on Amulsar mining.
January 25, 2022 at 15:13