EcoLur
Amulsar gold mining project is implemented by Lydian International LLC, the main shareholders are directors and top managers of the company - 8.00%, International Finance Corporation, IFC, - 8.1% shares and the European Bank for Reconstruction and Development, EBRD, - 6.9% shares. In Armenia Lydian is represented by a local company, “Geoteam” CJSC - 100% owned by Lydian. Amulsar gold mining is implemented and continues being implemented with various legislations of both national legislation and the principles of social and environmental responsibility declared by IFC. People’s constitutional rights to health and healthy environment guaranteed by Article 32 of the Armenian Constitution are also violated. Standards of IFC activities are violated:
-Ensuring environmental and social sustainability
-Rational use of resources and preventing environmental pollution
-Protection of health and ensuring the safety of population.
Amulsar ore contains, on average, 0.9 g/t gold, besides gold and silver it contains admixtures, including highly toxic lead, cadmium etc (see Hrachya Avagyan, Dr in Geological Sciences, “Ways and Prospects of Mining and Metallurgical Industries in the Republic of Armenia” Yerevan, 2011, “Gitutyun” Publishing House). The total concentration of toxic metals exceeds the concentration of gold and silver. The concentration of admixtures is submitted in the ore sample analysis carried out by Radman Association upon Lydian’s order. If 2.5 million ounces of fold is mined, 56 million tons of dumps with admixtures will be formed. The admixtures will pollute the main water resources in Armenia: water basins of Vorotan and Arpa Rivers, two reservoirs – Kechout and Vorotan, as well as Lake Sevan. The land areas surrounding Amulsar are exposed to pollution – pastures, meadows and protected territories. Thus, the Water Code of Armenia is violated (Article 98 “Protection of Interconnected Ecosystems and Landscapes” and Article 99 “Primary Requirements Towards the Protection of Water Resources”. Nevertheless, the company keeps silence about the presence of toxic admixtures and their impact on health and environment. The EIA project of Amulsar open pit mining submitted for environmental expertise also doesn’t say anything about the risks. Thus, the requirements of Article 5 of RA Law on ‘Environmental Impact Expert Assessment’ are violated in all three points.
Lake Sevan: The territory of Amulsar project, including its infrastructures – open mines, roads, heap leach facility, waste and industrial tail disposal facilities, warehouse facilities, including the warehouse for explosives are located in then catchment area of Lake Sevan in the immediate impact zone. Lake Sevan is a national and strategic priority in Armenia and Caucasus Region with its freshwater reserves of 35 billion cubic meters. Article 3 of RA Law “On Lake Sevan”, “Article 3: Kechout and Spandaryan reservoirs are a part of Lake Sevan catchment basin, as well as Arpa and Vorotan river catchment basins up to Kechout reservoir, while Articles 8 and 10 ban any activities having adverse impact on Lake Sevan ecosystem are banned in the central zone, in zones of direct and indirect impact. Geoteam company neglected RA Law ‘On Lake Sevan’ in the EIA of Amulsar project and didn’t consider probable risks for Lake Sevan ecosystem. But the Scientific-expert Committee on Lake Sevan Preservation gave its negative assessment to Amulsar open gold mining project, the authorities of the Scientific-expert Committee are laid down in Articles 19, 20 and 21 thereof.
Uranium: G. P. Aloyan’s article entitled “Resource Potential of Radioactive Raw Materials in Armenia and Its Development Perspectives” published in Russian “Mining Journal”, Issue N 6, 2007 proves uranium in Amulsar was estimated to amount up to 76 tons and thorium – 100 tons. The complainants think Amulsar open pit mining of gold quartzite may also touch uranium mine causing radiation contamination of territory, including Jermuk, Gndevaz, Saravan and Gorayk villages. The precise borders of uranium mine should be mapped to avoid it. The problem is that uranium is considered to be strategic raw material, while uranium exploration is the monopoly of Armenian-Russian Mining Organization under governmental resolution N234 dated on 06.03.2008, and not Geoteam Company and the organizations it cooperates with. So Geoteam Company’s all statements on uranium can’t be considered reliable, unless the company applies to Armenian-Russian Mining Organization requesting to map Amulsar uranium mine borders. Red-listed species: The findings of WWF Armenia studies in 2013 show that the following red-listed species have been detected in Amulsar and its adjacent areas: one plant species - Potentilla porphyrantha, two species of lizard, eighteen species of birds and four species of mammals – all red-listed in the Red Book of Armenia. The Amulsar Project EIA says, the project territory has only one species inhabiting – Caucasian brown bear. Thus, Article 26 of RA Code “On Subsoil” bans mining where the red-listed biodiversity is detected, as well as cultural and historical heritage sites, if they have: 1) burials; 2) monuments of nature, history and culture; 3) habitats of red-listed plants and animals, as well as migration corridors for animals.”
Jermuk Resort. Amulsar project poses essential risks for Jermuk resort located in a distance of 12 km from Amulsar. Under the government resolution “On Declaring Jermuk Town as a Tourism Center” № 1064-N dated on 18.09.2008 Jermuk was recognized as a tourism center. Under Jermuk Development Plan, the border of tourism zone approaches Amulsar in a distance of 2-4 km. Heap leach Facility: Lydian International Company started buying land areas in Gndevaz Village, where a tailing dump will be constructed. But the construction project of the heap leach facility doesn’t have any term like a tailing dump, but ‘waste landfill’ term. It doesn’t matter for the residents of Armenia and the region in general, who will be exposed to risks, what kind of term the company uses, if we speak about the risks of heap leaching technologies. It only shows the company’s desire to conceal real risks from the population and to hide reliable information.
Steps Taken to Solve Problems with Project Management The public have applied several times to IFC, Lydian and its Armenian subsidiary Geoteam Company for public consultations (see the application). Nevertheless, Geoteam company not only doesn’t take into consideration the opinions on project risks, but it also threatens. On 9 June 2012 “Jermuk Won’t Become a Mine” organized a hiking to Amoulsar with over 100 participants - representatives of the civic society. Geoteam Company (local representative of Lydian International) didn’t allow to enter the territory, but organized a rally of employees with posters of offending content addressed to activists (http://ecolur.org/en/news/mining/donvt-disturb-us-to-make-money-photos/3907/). Then, the company threatened to EcoLur, in reply to which EcoLur made a public statement http://ecolur.org/en/news/mining/ecolur-open-letter-to-quotgeoteamquot-cjsc/3924/.
The complainants have also applied to IFC official with Amulsar project risks: Regional Manager in South Caucasus Thomas Lubeck, Contact Representative in Armenia Anna Dira, Investment Officer Arman Barkhudaryan, but, unfortunately, no reply has been received (see attached letter to IFC). Instead of consultations and discussions of real risks, IFC neglected the opinions of a number of independent experts, hold consultation only with the company and replied on the opinion of company experts and doesn’t hold any consultations with the public. We think that Amulsar gold pit mining and heal leaching technologies can’t be implemented taking into consideration the essential risks for health and security of people violating the legislation, so we ask to stop the funding of Amulsar project as not complying with IFC high social and environmental standards.
March 26, 2014 at 12:38