On August 11, 2022, the second public hearing of EIA preliminary assessment application for geological prospecting planned for 2022-2025 for the reassessment study of nepheline syenite reserves of Tezhaget site in Tezhasar mine, Kotayk Region, organized by "Am Art Shin" LLC in Meghradzor settlement. Tsaghkadzor community, Armenia.
As a result of the discussion, the local residents expressed their opposition to the project for revaluation of the resources of Tezhasar mine. They drew up a written application to Tsaghkadzor Local Municipality to reject the application, under which they collected signatures.
We, the participants of public hearings, represented by Inga Zarafyan, President of "EcoLur" Informational NGO, Oleg Dulgarian, President of "Center for Community Mobilization and Support" NGO, Hakob Sanasaryan, President of Greens Union of Armenia, President of "Bird Lovers Center" NGO, Ecological Alliance Coordinator Silva Adamyan, members of "Healthy Hrazdan" environmental group Movses Manukyan and Arsen Arsenyan, appeal to "Environmental Impact Expert Assessment Center" of RA Environment Ministry with a request to reject the application for the re-evaluation of nepheline syenite reserves of Tezhaget site in Tejasar mine.
Substantiation
The negative opinion of the local residents about the project, which was voiced during the second public hearing and confirmed in the letter of rejection attached with the signatures, is a sufficient ground for the rejection of the application.
In the application, the reasons for the non-operation of the mine during the Soviet years are presented in a distorted form in the case of expenses of 117 million rubles.
In fact, according to Fadey Sargsyan, Academician of the National Academy of Sciences of the Republic of Armenia (Деловой экспресс, 2005, N 21), Tezhasar project was rejected during the Soviet years due to high risks and imperfect technologies.
What about the claim on "new technologies" mentioned in the application, the participants of the public discussion inquired about these technologies in terms of risk reduction. However, no answer was received from the representatives of "Am Art Shin" LLC, which allows us to conclude that there is no clear information about the introduction of new technologies.
The environmental impact assessment should have had more than sufficient professional depth and a strategic ecological assessment should have been carried out, which had not been performed.
Since there are already metal mines and a processing plant for their raw materials operating in the requested region, it was necessary to give an aggregate (cumulative) assessment of the impact of the activity, which had not been performed.
The company did not conduct field research to find out the presence of red-listed plant and animal species in the requested area. Despite the fact that "RESOURCE POTENTIAL OF RADIOACTIVE SURFACE OF ARMENIA AND PROSPECTS FOR ITS DEVELOPMENT" ("MINING JOURNAL, 2007, № 6 35 UDC 533.04:553.495 ©) research papers surely lays down that the content of uranium in the ore of Tezhasar mine reaches 0.09%, the company's application does not mention the content of radioactive materials. In addition to uranium and thorium, high contents of cerium and rare elements have been recorded, which will also be present in void rocks.
Inga Zarafyan - "EcoLur" Informational NGO
Oleg Dulgarian - "Center for Community Mobilization and Support" NGO
Hakob Sanasaryan – “Greens Union of Armenia” NGO
Silva Adamyan – “Center for Bird Lovers” NGO
Movses Manukyan – “Healthy Hrazdan” Environmental Group
Arsen Arsenyan - “Healthy Hrazdan” Environmental Group
August 15, 2022 at 16:44