(For background information on the case, click here.)
Edward Sellers, Interim President & CEO of Lydian Armenia, commented: “We [...] are confident [the Audit Report] will confirm Lydian’s prudential approach to environmental stewardship.”
In fact, the audit report does not entirely support Lydian’s claim of responsible environmental stewardship.
The report is essentially a review of the previous environmental and social impact assessment (ESIA) conducted by Lydian and does not take in account social and human rights impacts of the project. While it excludes the risk of contamination of Jermuk springs waters, it contains a number of worrying conclusions on the environmental assessment and monitoring plans conducted and developed by the company, stating that:
• “The ESIA/EIA assessments are deficient and corresponding conclusions are unreliable. Accordingly, the question of whether exploitation of the ore deposit can conclusively be considered safe cannot be answered.”
• “Several measures and plans are partial, not-sufficiently protective, and/or unreliable with a high degree of uncertainty, due to the deficient and questionable baseline characterization, data, models, design bases, and/or assessment”.
• “The acid-generating potential of the rock was calculated incorrectly.” “There is a clear potential for contamination of groundwater by [acid rock drainage]-impacted pit seepage water. This contamination would particularly affect nearby springs, which are important for local livestock and wildlife.”
• “The assessment excludes a value for damage to water resources based on the assumption that no contamination will occur. On this basis, the assessment of potential damages is unrealistic.”
• “Catastrophic earthquakes can cause a release of mine contact water and adversely impact groundwater and surface water within the Lake Sevan Immediate Impact Zone, particularly during the operation phase when large quantities of contact water are stored in ponds. Such releases will contaminate nearby springs and the Arpa River. The significance of the impacts on the Kechut and Vorotan Reservoirs and Darb River (and Sevan Lake) is uncertain because the models in the ESIA did not evaluate or quantify these impacts.”
This audit report thus raises further serious questions about the way Lydian’s ESIA was performed, the way that potential impacts were assessed, and the measures that the company has put in place to monitor such impacts. It also does not address some of the issues pointed out in a 2017 report by the Compliance Advisor Ombudsman of the International Finance Corporation (which has since terminated its investment in the project) on land acquisition and a lack of proper consultation with all affected communities, in particular with the Jermuk community that would be fundamentally impacted by the mine’s operations.
For these reasons, this audit report, while providing additional interesting and useful information, cannot be considered in any way a simple ‘green light’ to the company to pursue its operations in Amulsar region.
“Last year the Prime Minister Nikol Pashinyan stated that “If it turns out to be safe for Lake Sevan, Jermuk waters and water reservoir, we will allow the mine to be operated; if not we will choose a different way”.
This audit report confirms that the operations of Amulsar Gold Mine are far from safe for the environment and for the surrounding communities.
“We urge the Prime Minister to honor his statement and to value the people and the environment of Amulsar region and of Armenia more than investors’ interests,” asks Artak Kirakosyan, FIDH Vice President and Director of Civil Society Institute Armenia.