Statement on Amulsar Gold-bearing Quartzite Deposit Exploitation

Statement on Amulsar Gold-bearing Quartzite Deposit Exploitation

On February 22, 2023, RA government signed a tripartite memorandum of understanding with the Eurasian Development Bank and "Lydian Armenia" CJSC to resume Amulsar gold-bearing quartzite mining.

We, the representatives of the undersigned organizations and individuals, express our deep disappointment and displeasure regarding the illegal, short-sighted, irresponsible, adventurous, and fraught with dangers for the state decision of RA government regarding Amulsar mining.

The Government of Armenia has FAILED to:

1. Conduct a fully-fledged environmental impact assessment; it disregarded the results and conclusions of the respective studies by ELARD and TLC international organizations in 2019, that had been paid  $454 000 USD for their services from Armenia’s budget

2. Take into consideration the negative impact on the water resources, such as Lake Sevan, basins of Arpa and Vorotan rivers, Spandaryan and Kechut water reservoirs, the underground waters and the long-term pollution of the surficial and underground waters caused by acid and metalliferous drainage. 

3. Consider the radioactive risks at Amulsar deposit, since it contains uranium, thorium and radon; as well as the enormous masses of toxic dust that will rise and pollute the environment, should the mine be enacted. The cyanide technologies, banned in many countries globally, as well as the relevant risks, have also been neglected. 

4. Take into account the risk of losing Jermuk as a globally renowned spaand resort town. It's doomed to turn into a worker settlement, with the local population subsequently emigrating and the workers leaving it, too, upon the depletion of the deposit. 

5. Evaluate the health impact of the project. The minister of Health announced that the Amulsar project development is not hazardous for health and that the project had undergone the relevant expert assessments. This is not true, since either of the four environmental impact assessments conducted, contains any health hazard evaluation. This couldn’t have been feasible, since no respective methodology is available. 
6. Assess the negative impact of the project on “Jermuk” mineral water and consider Armenia’s commitment on preserving the biodiversity as per the Bern Convention on the Conservation of Wildlife and Natural Habitats. 

7. Take into account the continuous public resistance to the Amulsar project that the local community residents have been incessantly manifesting for years. In the fall of 2018 around 3 000 residents of the enlarged Jermuk community signed a public petition against metal mining industrial deployment in their territory. 

8.  Consider or do the due diligence with regard to “Lydian Armenia” CJSC’s style of conduct in the past- with all the illegal actions, violence towards citizens, the malicious practice of prosecuting people in courts that the company accounts for. Thus, the public resources were trusted to an offshore-registered company with unknown owners and financially challenging state of affairs. 

9. Give consideration to Azerbaijani aggression, the penetration of Azeri troops to Armenia’s territory in September 13, 2022 and the missile strikes on the town of Jermuk. According to the Amulsar project, there will be thousands of tons of poisonous and hazardous chemical substances that take centuries to disintegrate as well as explosives accumulated near the town of Jermuk. In the event of military actions, not only will this endanger Jermuk itself, but may cause, due to the leakages, the pollution of Lake Sevan, the entire Vayots Dzor, Suiniq and Ararat regions, where Arpa and Vorotan are the main water resources. Gegharquniq marz is running the same risk, because of Arpa-Sevan tunnel pollution. The statements regarding international investments as a safeguard to Amulsar project implementation are manipulative and lack any factual grounds. We are witnessing regular attacks in the Sotq gold mine territory, which clearly shows that no international investments can retain the Azerbaijani aggression. As for the Amulsar project, there is no evidence that a similar scenario can be avoided, and that Armenia’s territory is going to be less vulnerable because of the project. 

10. For the purposes of funding the Amulsar mining project, the Eurasian Development Bank was involved. The Government of Armenia failed to evaluate the political and economic risks of EDB’s involvement given the Western sanctions against Russia- a major stakeholder of the bank. Kazakhstan and Belarus, the other two large stakeholders of the Eurasian development Bank, have manifested a clear pro-Azerbaijani position during the recent war between Armenia and Azerbaijan. So, any deals with a bank with such stakeholders, would present a threat to Armenia’s security.  

The Government of Armenia, instead of adopting a policy to revitalize the once flourishing and now a borderline resort town of Jermuk, instead of restoring the normal life, empowering the community, and improving the borderline security, is now engaging in Amulsar mining project. In doing so, the government prefers to ultimately sacrifice Jermuk and its established social and economic systems for the sake of 10-11 years of revenues from the mining activity, for the sake of several billion drams to temporarily replenish Armenia’s budget, for the sake of prosperity of a few offshore entities. 
Considering the unmanageability of the risks of Amulsar project, we are against the implementation of Amulsar project.

We are demanding:

From RA President
·       To guarantee the observance of the Constitution of the Republic of Armenia and international norms, to express an impartial position regarding the economic, environmental, social and security risks threatening Armenia as a result of the implementation of Amulsar project, guided exclusively by national and nationwide interests.
·       To support the society in the fight against the dangerous project for the Republic of Armenia, to prevent the violation of the Constitution of the Republic of Armenia, to ensure national security and the environment.

From Ministry of Territorial Administration and Infrastructures:
·       To terminate the soil management agreement, the right granted to "Lidian Armenia" company, which was extended on 25.05.2022. due to the adopted anti-constitutional and anti-democratic RA Law "On Amendments and Addenda to Mining Code ".
From RA Health Ministry:
·       Publish the results of "all examinations" carried out by RA Health Ministry on the impact of Amulsar project and other mines on human health.

From RA Economy Ministry:
·       Publish the tripartite memorandum of understanding signed between RA Economy Ministry, Eurasian Development Bank and "Lydian Armenia" CJSC and the agreement on alienating part of the shares of "Lydian Armenia" CJSC to RA government.
From RA Environment Ministry:
·       To revoke the 2016 environmental assessment report for Amulsar project due to the incompletely assessed risks and emerging new environmental factors.

From RA General Prosecutor's Office
·       Initiate a criminal case and identify all the culprits, with the participation and permission of which the environmental impact assessment and expertise failures occurred, which laid the foundation for the bold advancement of the problematic Amulsar project.

From RA government:
·       Abandon Amulsar mine development project until financing is received, investments are made, and the Republic of Armenia has not assumed the financial burden to pay for the losses.

From international organizations accredited in RA
·       To support the implementation of human rights and democratic processes in Armenia for the sake of the Republic of Armenia and the security of its citizens.
1.     Transparency International Anti-Corruption Center
2.     " Center for Community Mobilization and Support " NGO
3.     "Ecological Law" NGO
4.     "Democratic Platform" Foundation
5.     "Human Rights Research Center" NGO
6.     "EcoLur" Informational NGO
7.     "Green Armenia" Environmental and Educational NGO
8.     "Forests of Armenia" Environmental NGO
9.     “Armenian Environmental Front” volunteer initiative
10.  "For equal rights" Educational Center NGO
11.  Freedom of Information Center
12.  "Helsinki Association" Human rights NGO
13.  "White Helsinki Group" Human rights NGO
14.  "Janus" Legal NGO
15.  "Vayots Dzor Evolution" NGO
16.  "Dalma-Sona" Educational, Cultural, Socio-Environmental Foundation
17.   "Ecological Public Union" NGO
18.  "Club of Journalists "Asparez"" NGO
19.  "Vanadzor Office of Helsinki Civil Assembly" NGO
20.  Zaruhi Hovhannisyan, Human Rights Defender
21.  Nikolay Davtyan, Director
22.  Roza Julhakyan, Expert
23. Law Development and Protection Foundation
24. “Peace Dialogue” NGO
25. “Human Rights Power” NGO
26. Gayane Shagoyan, cultural anthropologist

The  statement is open to join.

March 01, 2023 at 14:23