Nazeli Vardanyan, OSCE Expert
“Zangezour Copper and Molybdenum Combine” LLC has applied to Nature Protection Ministry to make amendments to the reserves of Qajaran copper and molybdenum mine. The following activities are planned: change in mining volumes, expansion of subsoil section and prolongation of permit term.
Studying the submitted documents it can be concluded that amendments to the mining project can cause serious environmental problems and violate the rules of RA legislation and international conventions.
Two large towns – Kapan (Syunik Regional Center) and Qajaran as well as 7 communities such as Qajaran, Lernadzor, Syunik, Atchanan, Artsvanik, Sevaqar and Chapni are in the impact zone of Qajaran copper and molybdenum mining. In rural communities the main directions of agriculture are cattle breeding, horticulture, bee, keeping. Many rural communities doesn’t deal with agriculture at all, as the tailing dumps are located in their areas, as well as there is no irrigation system. As a matter of fact, because of increase in mining volumes the social condition of community members will deteriorate and they will get deprived of their main means of living.
This project will also have a negative impact on the atmospheric air of project affected residential areas. The material submitted for expert assessment miss measures aimed at prevention of atmospheric air.
The whole area of Qajaran mine is located in the seismic active zone of Syunik Region. According to the EIA report, the location of the tailing dump belongs to I zone, the quantitative assessment of seismicity is characterized with maximum rate up to 8 magnitudes. Consequently, at any time, if a quake occurs, tailing dumps and combine may get damaged having leak of toxic and radioactive materials, which will result in endangering the whole population in the area. The EIA mentions about the seismic hazard of the area, nevertheless, it doesn’t plan any measure to prevent it or to mitigate its negative impact.
Mining causes pollution of rivers and groundwater basin. Increase in mining volumes and expansion of areas will add up the harmful impact on water resources. According to Article 99 of RA Water Code, “All water resources in the Republic of Armenia are subject to preservation.” All the rules of this article are violated.
Though the company has been mining for many years, increased mining volumes and received large amount of profits, it caused damage to the environment of affected communities, nevertheless, the population hasn’t been compensated. Many buildings in the communities were built in the 50-60s and became useless over the time: sevaqar, Chapni and Qajaran communities don’t have any kindergarten or school. The children in these communities have to attend schools in neighboring communities.
The EIA also ignored the rules of RA Subsoil Code.
Qajaran mine area is rich in biodiversity. The EIA says it’s the habitat of 214 plant species, a part of which is registered in RA Red Book. According to Article 16 of RA Law “On Flora”, “All objects of flora in the Republic of Armenia are subject to legal protection.”
RA Law “On Environmental Impact Assessment and Expertise” is also violated, particularly, measures to prevent impact on human health were not presented, the documents were not publicized on the website of the company and Nature Protection Ministry, no legal hearings were held and the access of NGO representatives and participation in the hearings was hindered.
Based on the aforementioned it can be concluded that the EIA on amendment to Qajaran Copper and Molybdenum Mining project has been carried out on surface not taking out a number of legislative requirements, the list of preventative measures hasn’t been presented in parallel with list of measures aimed at increase in well-being and health of project-affected community population.
October 27, 2016 at 16:29