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What does “new ecological factors” mean and why have previous concerns faded away?

Clarification of the statement published by the RA Environmental and Mining Inspection Department head on August 27, 2018 is necessary. The statement reads as follows: “Based on newly identified ecological factors, the RA Ministry of Nature Protection is recommended to declare to be no longer in force the Expert Opinion BP-35 approved by RA Minister of Nature Protection on 29.04.2016.”

First and foremost, it should be noted that in accordance with the law, EIA may be recognized to be no longer in force based on availability of “new ecological factors” or, for instance, activities carried out with deviations from design documentation that underwent expertise and requirements of expert opinion. Actually, as a basis for invalidating EIA the Inspection Department mentioned “new ecological factors” and not any “activities carried out with deviations from design documentation,” which means that the Inspection Department failed to detect any deviations from design documents in the Company’s activities, even despite its genuine efforts and desire to find one. Therefore, they had nothing to do but rely on alleged “new ecological factors.”

According to the Inspection Department, identification of Acantholimon caryophyllaceum Boiss plant species and Parnassius apollo animal species in the Amulsar area for the first time are “new ecological factors.”

About Acantholimon caryophyllaceum Boiss plant species

Acantholimon caryophyllaceum Boiss plant species was identified in the Amulsar area by biologist Anush Nersesyan, who was involved in the inspections by the Inspection Department. However, the individual species allegedly identified by Anush Nersesyan has not been presented to the Company yet. All indications are that either that species was not identified at all or it was identified outside the Amulsar area, since the “identification” process was concealed from the Company’s employees who accompanied Anush Nersesyan. Even if a plant species was found, Anush Nersesyan is not sure about its identification. After all, it was mentioned in the Inspection Report that the identified species is “most probably” Acantholimon caryophyllaceum Boiss plant species.   

It is noteworthy that according to the Company’s EIA (see page 220), this species of Acantholimongenus was known to grow in an area of Gndevaz village. 

  • Acantholimon caryophyllaceum: Gndevaz village area, upper stream of Arpa tributary. Frigana, eastern screes of volcanic rocks. Intermediate mountainous zone, 1600m. Collected in 1946 by A. Hakhverdov and N. Mirzoyeva.  

These species have not been collected from the Gndevaz village surroundings for the last 70 years.

For the EIA, a group of specialists from A.L. Takhtajyan Institute of Biology, RA NAS, including M.E. Hovhannisyan, conducted targeted searches in the Gndevaz village surroundings and Amulsar Mountain area. Unfortunately, searches were not successful, and the given species were not found in those areas.

Incidentally, as one can judge from the picture enclosed with the Inspection Report by the specialists involved by the Inspection Department, Anush Nersesyan picked the plant species that, as she claims, is “most probably” a RA Red-listed species. Arbitrary picking of RA Red-listed plants or their roots, flowers, or fruits is punishable under RA Code of Administrative Offences Article 93.  This clearly shows the qualification of the specialist who has no idea that picking a Red-listed plant species is an offence.   

About Parnassius apollo animal species

During baseline surveys of 2013, 60 species of butterflies, including Apollo (Parnassius apollo) species were identified in the area studied by the Company. Previously, this species was encountered in the proposed area of the Barren Rock Storage Facility (BRSF) (see ESIA report, Chapter 4.10. pages 67). However, under EIA expertise, the location of the BRSF was changed. As a result, the habitat of this species appeared to be outside the mine immediate impact zone. Therefore, it was not included in the EIA.  There is no scientific substantiation that the above area is habitat for this species.

Therefore, the “new ecological factors” identified by the Inspection Department are not new, since they were identified by the Company when preparing design documentation. The Inspection Department considers them as “new factors” just because it failed to find any deviations from design documentation in the Company’s activities. They have nothing to do but rely on assumed “new ecological factors.”

The Inspection Department has also declared that the Head of the Inspection Department has applied to the RA Prosecutor General with regard to the fact that Lydian Armenia has extracted rock mass without having any mining right. The General Prosecutor’s Office is recommended to determine the existence of a crime in this action, and to initiate proceedings in accordance with the established procedure.

In this light, it should be noted that the Inspection Department considered the existence of just two borrow pits as evidence of “extraction of mineral.” During our meetings with the Inspection Department, we have repeatedly asked them to clarify what minerals they think were extracted from those borrow pits. However, representatives of the Inspection Department failed to provide any clarification.

In accordance with RA Mining Code Article 3.1.17, extraction of mineral resources includes complex activities to extract minerals and recover valuable elements.

Furthermore, on July 30, 2018, as part of the Inspection Department’s inspections at Lydian Armenia CJSC, a tour of the Company’s construction site, and specifically the BRSF, was made.   The purpose of the inspection tour was to consider and assess (through sampling) the bulk material extracted from the borrow pit in the area of the proposed storage facility as clay soil. A. Grigoryan, head of Nature Protection and Mining Inspection Body, RA Ministry of Nature Protection, D. Arakelyan, geologist, member of Inspection Team, and T. Navasardyan, Company’s Environmental Officer, were present during the inspection tour.  The geologist studied the pit and clearly stated (literal quotation): “clay soil occurrences there are insignificant, and that area practically cannot be considered a potential source of clay soil extraction” (end of quotation). Taking into account this circumstance, the above area is a pit originated from preparations for construction activities and in no way shall be considered as a mineral extraction area.  

As regards the Inspection Department’s statement related to Yeghegnadzor Water Users Association and Jermuk Community Administration, it does not refer to Company and there is no need to address it.

In fact, the alleged “new ecological factors” that were revealed during the month-long inspections do not reflect the speculations related to impacts on water, air, soil and adjacent communities that arouse the “concern” of the individuals who have unlawfully blocked the roads leading to Amulsar. The resolution by the Inspection Department may be appealed in any superior authority and/or court of higher jurisdiction.

We’d like to recall that the Amulsar Project has always been and will remain the best project in the mining sector of Armenia for years to come, due to its environmental, social and safety standards. We are proud to pioneer a project of national and international importance.   

The Amulsar Project has already made a difference in our country – it has set a standard that may become impossible for others to achieve.  

 

Kind Regards,

Lydian Armenia Sustainability Team 

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