“Global Gold Mining” LLC has addressed a letter to EcoLur in regard with the opinion EcoLur submitted to Nature Protection Ministry on the construction project of the third tailing dump in Meliq Village after the public hearings at Nature Protection Ministry on 19 April.
This project has been submitted by Mego Gold Company (Armenian representation of GGM) to receive the opinion of the environmental expertise of Nature Protection Ministry.
The letter addressed to EcoLur particularly says, “We have to respond to the evident misinformation in the article entitled “EcoLur Opinion on Tailing Dump Construction Project in Meliq Village” published on 25.04.2013. Unfortunately we have to note this opinion contains misinformation…” and then “….still on 22 March 2013 the company made a statement where it responded to the ungrounded publication by EcoLur published by EcoLur…”
We state that we take part in the public hearings on this project under RA Law “On Environmental Impact Expert Assessment” and on the basis of UN Aarhus Convention “On Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters.'
The material having caused the reaction of Mega Gold Company is the official opinion of EcoLur submitted to Nature Protection Ministry about this project. The opinion doesn’t contain provisions or passages quoted by the company in its letter, which you may get convinced reading the text by EcoLur.
EcoLur has published a number of articles on the tailing dump construction project: video recording of two public hearings in Meliq Village, Nature Protection Minister’s statement, Public Environmental Alliance’s statement, the statement made by the Greens Union of Armenia, reply statement made by Global Gold Mining Company, i.e. officially published materials and press releases.
Following the informational policy adopted by EcoLur and responding to the company statement made on unpublished materials, we publish the text of the company statement and the statements of NGOs about GGM operation so far not published by EcoLur. You can read the full version in Armenian.
Public Environmental Coordinator Silva Adamyan and “Ecoright” NGO Chairman Arthur Grigoryan’s application to the US Ambassador to Armenia John Heffern
Dear Mr. Ambassador,
We have got acquainted with the State Department report on human rights situation in Armenia. Noting the great work done by the State Department we would like to mention with regret that the issue of human rights to live in healthy and comfortable environment was ignored in the report. Over the years this issue has been one of the priorities on the agenda of civil society, as well as the concern source repeatedly voiced by the international organizations.
The emerging civil society efforts to improve the situation of human environmental rights in our country are not legally simple both in governmental units and within the frames of public from the perspective of raising human legal consciousness. However, the obstacles almost become for us insurmountable when we have to deal with unfair mine exploiting companies. The latter, possessing the huge financial means and the other jacks’ impact, not only ruthlessly exploit the local population violating human rights and dignity, but also prevent the legitimate demands of the civil society representatives to have access to documents relating to the activities of these companies and to find ways of resolving the situation.
Unfortunately, it should be noted that Global Gold Company is one of the above-mentioned companies, which in addition to the above-described, shakes all over the world the American flag emphasizing of being protected by this powerful State. The above-mentioned company is apparently unconcerned about the fact, that by its activities it puts at stake the reputation of American people, best relative of the Armenian nation, and their State, as the people in Armenia are already well aware of the company's activities.
Mr. Ambassador, we’d like to ask you to direct your participation in this problem and, if possible, we offer to arrange a meeting with you for more details. We are also ready to organize your visits to Melikgyugh and Arevis communities where mining activity is carried out by the company.
We believe, Mr. Ambassador, that being a representative of a State, associated with democratic values and human rights protection, you won’t remain indifferent towards illegitimacy and injustice, which is carried out under the American flag.
Environmental Public Alliance Coordinator
Head of Eco rights NGO Arthur Grigoryan
Letter GGM N1
It has been for some time that some individual representatives of some NGOs in Armenia continue to make deliberately unsubstantiated, contradicting to facts and reality claims regarding the environmental situation at Toukhmanuk mine, including through internet and letters to various organizations and individuals.
Since November 2, 2012, the time when the Company transparently and openly presented the construction project for its next tailings dam to be constructed at Toukhmanuk property for public discussions, these individual representatives (including, specifically, Silva Adamian, representing Bird – Fanciers NGO, Hakop Sanasarian, representing Armenian Greens Association, Artur Grigorian, representing Ecoright NGO, and others), started posting claims that contradict the reality regarding Toukhmanuk new tailings dam, specifically, and the activities of Mego Gold in general, in the internet and media.
Deliberate, and often simply insulting statements and claims were made, including, through selectively presenting, by falsely misrepresenting and misinterpreting the different parts of the Toukhmanuk new tailings dam construction project documents, often twisting and forging the clear and undeniable facts and realities, including through acting “unaware” about well known facts and realities, for the purposes of a deliberate and smear propaganda agasnt the Company’s activities.
Thus, during November 2012, through some internet and media publications, these individuals claimed, that (i) “Mego Gold is going to contstruct a tailings dam with a territory of about 7 hectares”, (while, in fact, the territory of the tailings dam is only 1,53 hectares, according to presented project documents), (ii) due to Mego Gold activities “no babies are born in Melikgyough anymore”, or “infant natality became almost zero”, (while, in fact, only in 2012, 25 babies were born in Melikgyough, and 7 more babies were born since January 2013 until now, i.e., infant natality rate in Melikgyough is higher than average rate in Armenia by 1,7 times), (iii) due to activities of Mego Gold “the cases of cancer disease multiplied in the community”, (while, in fact, during the activities of Mego Gold since 2008 only three cases of cancer was registered in the community, all patients being older than the age of 75, i.e. only 0,26% of the community, while the average rate in Armenia is 1%, and, for example, another community with the same population in the same province, Katnakhpyur, that has no mining property or any industrial activities around, registered 18 cases of cancer, i.e., 6 times more than in Melikgyough, during the same period), (iv) “there were numerous cases of accidents at the tailings dam, and it collapsed”, (while, in fact, there were no accidents at tailings dam, and it never collapsed, there were no such signals even from unofficial sources), (v) that “no one knows about the mining plan”, “the public is not being informed about such plans”, and, “only small amount of information was possible to extract forcefully”, (while, in fact, the mining plan, including the open pit plan, treatment plant plan, and the tailings dam plan were prepared, examined, including for environmental and health protection aspects, filed and subjected to special expertise, including through public hearings with participation of the representatives of the community back in 2008, and these plans, along with all accompanying documents, are available at the respective bodies and at the Company, all publicly available, including pursuant to Armenian Law on Freedom of Information), (vi) due to activities of Mego Gold “land fertility declined multiple times”, “villagers reap no harvest”, “land fertility dropped, fields are being destroyed and deserted”, “huge damage is caused to the community’s agriculture”, (while, in fact, the harvest of oat as a general culture raised in the community during 2012 was record high, for non – irrigational lands, amounting 25 metric centners/ha, the potato harvest was also much higher than the average, amounting 35 tonns/ha), (vii) due to activities of Mego Gold “territory necessary for cattle breading dramatically declined”, (while, in fact, Mego Gold is using only industrial lands, Melikgyough community agricultural lands territory amounts to 2,337.3 hectares, vs. Mego Gold mining territory amounting to only 46,7 hectares, i.e., only 2% of territory compared to the community’s agricultural lands), (viii) that “drinking water is contaminated, because the tailings infiltrate the irrigation water”, “the quality of drinking and irrigation water supplied to Melikgyough dramatically worsened), (while, in fact, Mego Gold conducts permanent environmental monitoring in and around Toukhmanuk property through an independent expert organization, since 2006, such monitoring including some 23 elements, including the metals, the results are disclosed by the expert organization to the community, local government, state bodies, NGOs, and also posted on the internet, during these 6 years of monitoring no cases of any release of any element into the environment, including into the drinking and irrigation water of Melikgyough, was recorded), (ix) that “water generation and water supply systems are breached and destroyed”, that “it is impossible not to breach or destroy water generation systems, since property exploited by the Company is the part of such system of water generation and water supply”, (while, in fact, the territory of such water generation and water supply is consisting of 80 to 100 square kilometers, comprising the most part of the Tsakhunyats plato, while the mining territory of Mego Gold is only 0,46 square kilometers, i.e., only 0,46% or 0,57% of the whole water generation and supply system, and all water generation and supply systems are being preserved even in the mining territory of the property).
Aside from these claims, there were also other, numerous, deliberately false and fabricated claims, from the same individual representatives. Generally, individuals making these claims are not only well aware about the nature of their claims being false and fabricated. They are also aware that the Company and Mego Gold are taking care and spend big amount attention towards the environment, and that they never breached any environmental rule or statute.
Besides these clams, the same individuals made public claims of simply insulting and defamatory character against the Company and its employees, publicly calling them “parorexia”, “thief”, “exploiter of the poor”, and other, publically called the community members“cowards” and “corrupt”, the community residents who disagreed with their false statements as “traitors”, and the fact of the community official consent to construct of the new tailings dam as a “bargain”. The offenders, presumably, are all educated, some with scientific titles, all considering themselves as public representatives, while the norms of civilized manners, and not this obscene behavior, shall be typical to public or any of its representatives. One of the offenders, for example, went so far in his own manipulation and twisting of the reality, that publically accused the CEO of the Company, a descendant of the generation escaping the Genocide and living in Diaspora, whose track of record in international recognition of the Genocide is evident and undeniable, in “intention to take part in the Genocide”.
Afterwards, in a clear attempt to “implement” the false and fabricated claims already made deliberately and disseminated, Silva Adamyan, on behalf of the Ecological Public Alliance, appealed to the Prime Minister and the Minister of Environment of Armenia, and demanded to “stop all the activities of Mego Gold”, referencing to the same false accusations made.
Considering that the deliberate manipulation and twisting the facts and reality shall have a potential of causing damage to the reputation of the same NGOs that these individuals are representing, and also considering, that the same individuals shall be concerned about such damaged reputation at the first place, the Company came up with a public statement in January 31, 2012, pointing to factual evidence, and called to refrain from damaging the reputation of the NGOs and the public representatives, refrain from disseminating obscurantism and considering the clear evidence and scientific substantiation instead, refrain from insulting the Company, its employees and the community residents, and offered a good faith cooperation with the Company in its everyday work aimed at protection of the environment.
Instead of accepting the reasonable offer made by the Company which would be acceptable to any true public representative, the same individuals, without even trying to refute any of the evidence or expert test results and scientific substantiation provided by the Company, tried to continue disseminating the same false and fabricated claims against the Company, through changing the ways of manipulation only.
First, an attempt was made to accuse the Company as if the latter “conceals” its mining plans and documents from the public. Furthermore, these individuals, while acting as falsely unaware, attempted to accuse the Company in “publically refuting” the presence of metals in the tailings dam, accused the Company in concealing the methodic by which the project documents were prepared”, demanded “expert information” (as if such information was not disclosed the public), and, furthermore, claimed as if the information contained in a scientific work that was published in 2010 (Sh. Khachatryan, “Geological and chemical specifications of the Toukhmanuk Gold Mine”) contradicted the information provided by the Company, and further claimed that the Company, its officers and specialists “deliberately mislead the public, by concealing the content of the tailings to be placed in the tailings dam and their potential effect on the health of the residents of the community and the entire region”.
In fact, however, in November 27, 2012, the Company presented only the construction project of its new tailings dam to be constructed for the public hearings, including the environmental study for the construction of the tailings dam. While, in fact, the Company presented and implemented the public hearings for Toukhmanuk mining plan back in April 21, 2006, in the community hall of Melikgyough village, in presence of hundreds of attendees. For the purposes of such hearings, the Toukhmanuk mining plan, including the open pit plan, treatment plant plan, and the tailings dam construction plan were presented and publically discussed, along with any and all accompanying documents, analysis, and scientific reports, consisting of hundreds of pages of documents. Community officials, residents, public figures, intellectuals, National Assembly members, specialists, NGO representatives, reporters, local clergy members, and others simply interested in the Toukhmanuk project attended the hearings (please see the pictures attached). The hearings took almost all day. In the result, the detailed project documents, along with expert and scientific substantiations, were filed to the Ministry of Environment, along with the community’s consent for the project to commence, and for expert examination. In the result of the expert examination, conducted in all detail and scrutiny, the Environmental Approval for Toukhmanuk Mining Plan was issued. All the documents presented at the hearings, then presented for the Approval, and even after the hearings and such Approval, are publically available at the official bodies and the Company, pursuant to Armenian Law on Freedom of Information.
Besides these open, transparent and public proceedings of 2008, the Company prepared and filed the results of its massive geological exploration of Toukhmanuk ore field in 2006, consisting of the result of diamond drilling of 25,000 meters, surface and trench sampling, and scientific report for this exploration. All these documents are also publically available. In the result of the Company’s scientific research, the Toukhmanuk Pre Feasibility Study (including the environmental impact study), the Toukhmanuk Metallurgical Reports (four of them, for the years of 2008, 2009, and 2010), also the Company’s “Toukhmanuk Geological Exploration Report” for 2009, were all prepared, and filed for approval of Toukhmanuk reserves at the Ministry of Energy and Natural Resources. All these documents are publically available, and the proceedings at the Ministry were all open for public. In fact, the scientists (Sh. Khachaturyan), who, according to the accusers, “revealed” the “concealed” information by the Company, co – authored the Company’s “Toukhmanuk Geologcial Exploration Report”, and the scientific work he published in 2010 is just the brief version of the Company’s 2006 Report.
One specific episode of attempts to falsely accuse the Company by these individuals is typical: in their fabricated attempt to “reveal the truth”, one of this individuals, without notifying the Company or inviting the Company to participate, and secretly from the Company, initiated “sampling the tailings dam and the soils from the yards of the villagers of Melikgyough”, then falsely announced about“revealing the concealed by the Company concentrations of some elements that exceed the limits provided under the law”, and placed the statements in the internet, without analyzing, immediately.
For legal consideration, it is worth to mention, that Armenian law (like the laws of other countries) does not provide “limits for concentration of elements in the tailings”. Such statement is a mere manipulation, and is aimed at misleading. The tailings are wastes, they are neither eatable, nor drinkable, for the law to provide limits of concentration of any elements in them. The waste is preserved in the tailings dams, and isolated from the outside environment, just because it is waste. Moreover, Armenian law considers the waste from mining (tailings) as “non – dangerous” waste. This is a clear and known fact.
The same individuals, by the way, repeatedly refused the Company’s offer to participate in the independent permanent environmental monitoring, and even analyze the duplicates of the samples in alternative laboratories, just to make sure that the results of the monitoring are correct. The Company discovered only recently the reasons for such refusal to participate, by the mentioned individuals.
Although the results of the lab assessments made by the representative of NGO were not provided to the Company, the Company was able to acquire them (see attached). According to the assessment made by one of the labs of the Armenian National Academy of Science, the concentration (mg/kg) of barium (BA) in the soil of the yards of villagers exceeds the concentration of the same element in the Company’s tailings (waste) by up to 2,2 times, cobalt (Co) by 2,1 times , crome (Cr) by 2,3 times, copper (Co) by 1,8 times, nikel (Ni) by 1,9 times, rubidium (Rb) by 1,4 times, tin (Sn) by 2,3 times, stroncium (Sr) by 2,8 times, vanadium (V) by 2,3 times, zinc (Zn) by 15,2 times, circonium (Zr) by 2 times, iron (Fe) by 2 times, titan (Ti) by 2 times.
According to this assessment, and the logic of concentration of different elements, even if the Company tailings were not only released (which is ruled out by the independent and permanent environmental monitoring), but entirely replaced the soils (which is impossible), the concentration of these elements would be much less than those in the waste. It is also evident, that the Company waste is much “cleaner”, in consideration of the concentration of these elements, than the soils of the villagers. If the concentration of these elements in the soil was simply compared with the same concentrations in the tailings, and given a simple analysis, logically, the representatives should had thought of something else than falsely accusing the Company in contaminating the soil.
Apparently, the villagers themselves told the representatives that they are well aware, and were aware for a long time, of the concentration of at least some of these elements in their soils even before the Company activities began (during one of the meeting organized by the representatives at the community, to which the Company was not even invited), since back in soviet times large amounts of different chemicals were widely used in the community against rodents, and other chemicals as fertilizers, and even after the soviet government’s banning them, these chemicals were not removed from the village, but buried in their soils instead, massively. Fertilizers are still being used. Apparently, the representatives knew about it, but choose to falsely accuse the Company instead, and even disseminated a public statement claiming, as if, that the Company “is refuting the results of the assessment” made by these representatives. Instead, the Company is expecting that these individual representatives themselves should refute their own statements against the Company.
Moreover, understanding full well that their accusations against the Company are entirely false and fabricated, the same representatives organized different meetings at the Community, as if to discuss the activity of the Company, but did not invite the Company or its representatives to such meetings. During these meetings these individual representatives are trying, through spreading a mere obscurantism, provoke some individual residents to make false statements against the Company purely for a smear propaganda purposes. For example, during one of the meetings where the Company representatives participated without being invited, an NGO representative stated that the Company officers shall be “sentenced to death by hanging” , not for harming the environment, but for just mining the property, since mining is “evil”, many other countries banned mining at all and officially, as mining itself if harmful, but encourage their companies mining in Armenia instead (such as Germany).
Company representatives witnessed during the same meeting, that a specific person representing an NGO, would invite some individual residents he personally knew out of the discussion room, coached them what to say when back in the discussion room, while the other individual representative would videotape in detail the resident’s yelling and simply cursing, and placing the video in the internet later, as if a bright evidence of the communities “resistance”. This behavior was not even being concealed, and no footages are placed in the internet by these individual representatives, where the community members not only disagree with their false accusation, but also oppose them. As a result, artificially fabricated nature of the footages placed in the internet by these individual representatives is apparent.
This, indeed, is a disguised behavior. It is clear that some NGO representatives apparently trying to put obstacles, and even stop the activities of a company the record of which clearly provides that the company not only proved its dedication to preventing any violations of the environment, not only proved its dedication to social responsibility, but also considered these issues as a top priority. However, not only the false accusations against the Company don’t stop, but escalate instead, through dirty tactics.
Company’s attempts to investigate such odd behavior resulted into sad revelations that the Company is disclosing herein.
The Company was informed that some of these individual representatives, apparently, applied to some international and local sources asking for financing against environmental violations at Toukhmanuk, often repeatedly and morbidly insisting. The Company was also informed, that some international sources told these individual representatives, that taking into account the transparent activities of the Company, there are simply no evidence of any environmental violations at Toukhmanuk, and there is an absolute absence of any public awareness of such violations. Apparently, these individual representatives understood the advice differently: public awareness can be fabricated, and the evidence falsified. This is a simple soviet approach, which does not lead to any results anymore.
The Company is still investigating the advice provided to these individual representatives by the local sources to finance for hindering or stopping the Company activities, however, the Company’s specific revelations currently available are also disturbing. It has been for weeks, that one of these individual representatives, for example, is posting in her personal facebook account (through opening a special group) the materials posted in the internet and media a while ago, for the purposes of smear propaganda initiated by a former government official in the context of that official’s corrupt demands against the Company. This specific individual representative became so exited, that even posted, and tried getting “likes” from facebook audience, on the media reports about another company’s activities with the same name (Global Gold), in Kirgizia.
This behavior is extremely concerning, is harmful to the country, the industry, the economy, facilitates the emigration – already a problem for the country, is harmful for the reputation of NGOs, and shall be stopped immediately. Representing group or individual interest by individual representatives of NGOs, and their copying corrupt officials’ behavior cannot be allowed. Armenia deserves to have environmental NGO truly dedicated at protection of the environment of the country.
In light of these realities, the Company is hereby requesting these individual representatives to disclose the international and local sources their applied for their activities regarding Toukhmanuk mine, and the purposes and conditions for such activities.
The Company will continue working transparently and openly, including for the protection of the environment. As always, we are open for any discussion that is aimed at serving interests of the communities of the Company’s operations.
Global Gold Mining, LLC Armenia Branch
May 02, 2013 at 16:30