On 2 February 2014 the Public Environmental Alliance has addressed an open letter to Nature Protection Minister Aram Harutyunyan in regard with the third project of Tikhmanuk mine tailing dump. The Alliance thinks that the project should be issued a negative opinion with the substantiation of principal and professional drawbacks. The letter says:
1. The project has been submitted without mine development component,
2. “MegoGold” LLC hasn’t so far performed the requirements of the new (second) tailing dump of Tukhmanuk gold dressing facility as laid down in the environmental impact expert opinion issued as of 20.02.2007. The working project for the rehabilitation of the Tukhmanuk mine gold dressing facility says flotation method will be used as a dressing technology, while the positive opinion issued by the Nature Protection Ministry on the second tailing dump says that the use of chemicals or reagents isn’t planned in the technological process of the ore dressing process.
3. From the professional viewpoint the project is incomplete, particularly:
a) The analyses and assessments of the current ecological situation of surface and underground water, air layer, ground and ecosystem in general are missing,
b) Only abrupt and non-substantiated data are laid down without assessments and analysis,
c) No environmental impact expert assessment hasn’t been performed, as a matter of fact, any assessment, scenario and action plan isn’t available.
Based on the aforementioned we think that the working project of constructing the third tailing dump for Tukhmanuk gold mine in Aragatsotn Region is not eligible to consideration substantiating with principle and professional drawbacks and should be issued a positive opinion.”
18:35 February 11, 2014