April 14, 2023 letter translated from Armenian.
For the attention of:
- The Prime Minister of the Republic of Armenia, Mr. Nikol Pashinyan,
- RA Minister of Economy, Mr. Vahan Kerobyan,
- RA Minister of Health, Mrs. Anahit Avanesyan,
- RA Minister of Environment, Mr. Hakob Simidyan,
Subject: If you want to destroy Armenia once and for all, restart the Amulsar project.
Based on your recent decision to restart the Amulsar gold mine project, I would like to present our detailed studies and evaluations of this project for your consideration and evaluation, hoping that you will reconsider your decision.
This is the most comprehensive evaluation of the Amulsar gold mine project to date.
Below is your news media information about your decision to restart the Amulsar project. A few Google translated.
https://www-aravot-am.translate.goog/2023/03/14/1328707/?_x_tr_sl=hy&_x_tr_tl=en&_x_tr_hl=en “After 4-5 years of suffering, suffering and study, we signed a memorandum.” Pashinyan about Amulsar
https://www.youtube.com/watch?v=HU6gehksHOg Amulsar mine will be exploited. The memorandum of understanding was signed (in Armenian and English)
https://armenpress-am.translate.goog/arm/news/1104853.html?_x_tr_sl=hy&_x_tr_tl=en&_x_tr_hl=en Minister of Health Avanesyan is sure that the Amulsar mine will be operated in accordance with the standards so that citizens’ health will not be harmed.
The purpose of this power point presentation is to evaluate the feasibility of the Lydian Amulsar gold mine project and to identify related technical, environmental and contractual facts, issues and risks for all stakeholders to make better decisions on the feasibility of this project.
The problem is that the newly formed US Lydian Company, formed in 2005, also registered in the UK as an offshore company and in Armenia as Lydian Armenia, has no prior experience and track record in the mining industry, has incomplete and unsatisfactory evaluations and guarantees, and has never implemented such a chemically and environmentally hazardous project anywhere. Lydian’s first and only project is Amulsar, located in the heart of Armenia’s water resources.
The location of Amulsar as shown here https://goo.gl/rx1pi5 and here http://bit.ly/2JKnvep, is the most important risk factor, located between three rivers (Arpa, Darb and Vorotan), two reservoirs (Spanadaryan and Ketchut), an underground tunnel, located near Jermuk, which will also affect Lake Sevan. Groundwater flow paths predicted by Lydian during the operational period from the mine https://goo.gl/hJjKPY and after the mine closure https://goo.gl/tky7zR from this Lydian document https://goo.gl/MhEkX4 make this project vulnerable to any mining activity in Amulsar. Let Lydian clarify what will happen to the surrounding surface and ground watersdue to acid mine drainage and how Lydian will stop the pollution created? Due to uncontrollably high levels of acid drainage, what do you think can happen to the heart of Armenia’s best water resources for hundreds of years? In general, mining activities should not be close to important water resources, which is the case in Amulsar.
Another important risk factor is the composition of the ore deposit, 0.75 grams of gold per ton of deposit. That means extensive destruction of the Amulsar area and its surroundings.
Please watch the late academician Armen Saghatelyan’s interview in Armenian below for a detailed explanation of the risks posed by acid drainage.
https://www.youtube.com/watch?v=m5lxLRtBaKw Ամուլսարի հանքի շահագործման խնդիրները: Պրոֆ. Արմեն Սաղաթելյան
It seems to me that after so many years, the current and former authorities of Armenia have not seriously assessed the risks and consequences of the Amulsar gold mine project in the heart of Armenia’s water resources, by the Lydian company, which has not implemented any mining project anywhere in the world. The surprising fact is that although the positive financial benefits are mentioned above by the RA government, the environmental and economic losses are not mentioned. Why? One can conclude that all the facts presented by environmentalists and us for about 10 years have been put aside. I hope that our final documents regarding the environmental and economic risks and consequences arising from it, which I am presenting here, will not be ignored either.
And what positive environmental, social and economic studies and conclusions forced the RA Prime Minister and the RA government to make a decision and move forward with the Amulsar project? Is that information publicly available? What environmental guarantees has Lydian provided for this project?
I would like to inform you that since 2014, I have been directly involved in the study and evaluation of the Amulsar project, when Lydian presented the Amulsar project to a group of Armenians in the United States.
My involvement with environmental issues in Armenia began in 1989, when I invited 5 environmental, scientific and academic experts from Armenia to Los Angeles and introduced them to environmental progress in the United States. In 1992, I taught a number of courses on “Industrial wastewater treatment technologies” at Yerevan Polytechnic Institute and Yerevan State University. Then we started a master’s degree program at the Polytechnic University in the field of Environmental Engineering. I also designed, supplied and supervised the installation of 2 sewage treatment plants in Armenia in 2003 for James Tufenkian hotels in Tsapatagh, near Lake Sevan, and in Tsoraked near Vanadzor.
As a Chemical/Environmental Engineer with 23 years experience in water, sewage and industrial wastewater treatment projects in Saudi Arabia, USA and Armenia, I contacted 4 independent highly experienced international mining consultants from Australia, USA and Canada, to evaluate the Lydian documents.
Between 2017 and 2020, we reviewed 27 original Lydian English documents, thousands of pages, which were posted on Lydian’s website, in addition to 11 documents prepared for Lydian related to the Amulsar project, including 2 documents from Elard consulting company from Lebanon, conducting an independent evaluation of the impact of the project. As a result, we prepared 19 reports that analyze in detail the problems and risks of the Amulsar project. All these documents can be found in our final summary in English here https://bit.ly/3ITAWr2 , and the Armenian translation of the summary of risks involved in Amulsar here. https://bit.ly/40jOIsU
In June 2018, I brought two of my consultants to Armenia, and we had meetings with the RA Ministry of Nature Protection, the RA Government, the US embassy representatives, several representatives of Lydian and visited the Amulsar site. We had several other public meetings.
When any project, especially a mining project, is to be evaluated, the short-term and long-term technical, environmental, social and economic benefits and harms of the project must be assessed, including any alternative project options. For example, Jermuk’s mineral water, tourism, healthcare or agriculture can provide sustainable economic growth without the negative environmental, economic and social impacts associated with mining. Without such an approach, it is impossible to make effective and logical decisions about any project. Have such studies and assessments been carried out and presented to the public by the RA Ministries of Environment, Economy and Health?
Amulsar is a short-term 10-year project. However, its negative environmental, economic and health impacts on water resources will begin and continue for hundreds of years. Those who have a job will be unemployed after 10 years and will have uncertain job opportunities.
Do you have highly qualified engineers, scientists and economists in your ministries who can evaluate such projects in English when you are dealing with international companies? Mining is a highly technical and risky activity that has very serious short-term and long-term environmental consequences. How fully have you assessed the Amulsar project and its short-term and long-term impacts and consequences on Armenia’s most important water resources?
Amulsar’s risk summary is presented on the first 6 pages of the final summary of our September 11, 2020 document in English here https://bit.ly/3ITAWr2 for your review. Please read.
The Major Risks Developing in the Amulsar Gold Project
Nearly all risks related to development of the Amulsar Gold Project ultimately result in an increased potential for water pollution. The risks are presented in an order that builds from one to the next. Taken together, the risks increase the likelihood that the surface water, springs, and groundwater on and around the Amulsar site will become and remain contaminated.
- Risk #1: Acid rock drainage will form.
- Risk #2: Mitigation measures proposed by Lydian to prevent ARD and contaminant leaching will fail.
- Risk #3: Mine-influenced water will be inadequately captured and treated.
- Risk #4: Mine facilities will fail to contain contaminants because of poor design, uncertain water balance, and lack of consideration of climate change
- Risk #5: Valued water resources will become contaminated and depleted.
- Risk #6: The Armenian government and citizens will be left to clean up the mine and its impacts.
Additional risks: Dust and noise
Summary of Risks of the Amulsar Gold Project
The primary reasons for the high probability and consequences, and therefore risks, at the Amulsar Gold Project are summarized as follows:
The probability of poor environmental performance is high due to the following primary reasons:
- Inherent factors of elevated Acid Rock Drainage (ARD) potential and close proximity to water resources both occur at Amulsar.
- Lydian is not using international best practice for geochemical and hydrologic characterization, ARD mitigation measures, or mine water treatment.
- A high proportion of large-scale mines, even in countries with stronger regulatory and enforcement frameworks than Armenia’s, have had accidents and failures that caused contamination of water resources.
- Lydian has no prior experience with mining and little capital.
- The mine facilities, including the pits, waste rock pile, and heap leach facility, will remain on the site and continue to leach contaminants in perpetuity.
- Lydian has an inadequate bond amount to cover perpetual mine water treatment or failures if the mine closes early.
The consequences of a failure are high for the following reasons:
- The Amulsar Project is located in the headwaters of three rivers that feed directly into the country’s water supply and distribution network.
- Armenia has a semi-arid climate with a limited water supply.
- Climate change will further stress water sources and increase chances that mine facilities will fail.
- The main mine contaminants – cyanide, acidity, and metals – are highly toxic to humans and aquatic life.
- Armenia’s agriculture and tourism industries depend on a clean environment and waters that are not impacted by mining.
Taking into consideration the numerous risks of the Amulsar Project, seriously reconsidering the viability of this project can be the best approach to prevent adverse impacts to the environment and the Armenian people.
This final document https://bit.ly/3ITAWr2 also includes the following.
- Appendix 1. List of Reports and Memoranda Produced by the Bronozian Consultants about the Amulsar Gold Project
- Appendix 2. List of Amulsar Gold Project Documents Reviewed by the Bronozian Consultants
- Appendix 3: Outcomes and Costs: U.S. Mines with Similar Characteristics to Amulsar
I have prepared a Power Point presentation in 2019 about the environmental, technical and contractual aspects of the Amulsar project, including risks, here: https://bit.ly/3kBEg0U. I believe that by reviewing this document, you will have additional information related to this project.
My interview in Armenian in Yerevan in June 2018, also presents the problems and risks associated with the Amulsar project and will better help you make your decisions.
https://www.youtube.com/watch?v=BzFOrH2lYgo&t=184s There are people or reasons that wanted to start this program without considering the will of the people.
You can review the qualifications of my 4 international independent mining consultants here: https://bit.ly/3EEKbZQ
You can review my qualifications here: https://bit.ly/3krx5Iq
Our above detailed studies and evaluations of the Amulsar project can guide you to make your final decision about this project. This is the most comprehensive evaluation of the Amulsar gold mine project to date.
First problem, guarantees.
My answers to RA Economy Minister Vahan Kerobyan in red letters.
Amulsar mine will be exploited. an increase of 1 percent of Armenia’s GDP is predicted (Google translated).
Amulsar mine will be exploited. The Memorandum of Understanding was signed between the Government, the Eurasian Development Bank and the Lydian Armenia company. In exchange for the operation of the Amulsar gold mine, the Armenian government will receive 12.5 percent of the shares of the Lydian Armenia company.
Vahan Kerobyan (Minister of Economy of the Republic of Armenia) – We will not pay anything in return, but instead we will insure the transaction as a shareholder.
That is the biggest contractual mistake anyone can make with any project, especially a multi-risk mining project like Amulsar, that will continue for hundreds of years due to acid drainage. Responsibility for any such project rests with the company implementing the project, not the client. How can the Armenian government assume responsibility for the risks of the Amulsar project without examining the numerous risks of the project in detail? And what guarantees did Lydian give to the Armenian government, on the basis of which an agreement was reached between the two parties? Does the RA Ministry of Economy have an explanation for this?
A total of 250 million dollars will be invested. The money will be used to complete the construction works and purchase the necessary technical equipment. The company will provide $7 million in support annually to affected communities.
First, does anyone know how much work has been done and how much more work needs to be done to restart the Amulsar project before the construction work is completed and the necessary technical equipment is procured? Is it 20%, 30% 50% or more? This information is important to know in order to find out how easily this project can be canceled and freed from the dangerous effects of the Amulsar project. A team of independent engineers must visit the Amulsar site and investigate. It is best to stop this project now, because in the short and long term, over hundreds of years, the disastrous losses of this project will far outweigh the benefits. If the Armenian government, the people and the Diaspora do not understand this fact, then we are our own enemies and we cannot blame Lydian for the destructive consequences of this project.
What income will the community have after 10 years?
Vahan Kerobyan – “Lydian Armenia” will create hundreds of jobs in the affected communities and will provide significant economic growth and activity not only for the region, but also for the Republic of Armenia as a whole.
It seems that what matters for the Armenian government are short term results. However, are the jobs created equivalent to the unavoidable environmental disasters produced under the conditions of mine operation. The sad conclusion that can be drawn from the activities of the heads of the RA state bodies is that they seem not particularly concerned about the future of the Armenian people.
This is a 10-year project. What income will the community have after 10 years? And what losses will occur during the 10 years and after for hundreds of years.
Touching upon the environmental issues in the case of Amulsar mine operation, the minister noted that all studies have been carried out according to Armenian legislation.
What studies have been done by the Armenian government, who did them and where is the evidence? Compare them with our 3 year studies here https://bit.ly/3ITAWr2
Vahan Kerobyan – Lydian Armenia currently has all the necessary permits to start work. That is, there is no legal obstacle for the company to carry out its activities.
Where is that assessment of the Amulsar project on the basis of which permission was given by the Armenian government to restart this project?
The negative and destructive consequences of Amulsar gold mine exploitation will affect all water resources, including Jermuk and Lake Sevan, for centuries. As a result, the long-term losses will be many times greater than the short-term gains and benefits in 10 years. So why does the Armenian government still want to implement this project?
According to Geoffrey Koch, a member of the board of directors of Lydian Armenia, Amulsar is a new generation mine with the highest environmental standards.
We have already proven that this is not the case, and Lydian’s assessments have many environmental flaws.
Jeffrey Koch (Member of the Board of Directors of Lydian Armenia) – During this time, we have carried out works to operate the mine with leading technologies, we have implemented international best practices. This will be one of the best programs of Armenia’s economy, which will provide 100s of high-paying jobs, large taxes. It will also facilitate the introduction of new business projects and support services.
First of all, Lydian has not done mining anywhere in the world to be able to speak about international standards. The technologies used in this project are not leading technologies. This project is only for 10 years, after that what jobs can the RA government guarantee and who will cleanup the resulting surface and groundwater contaminants for perpetuity?
It is estimated that with the operation of the Amulsar mine, Armenia’s GDP will increase by 1 percent. It is quite a high indicator, and we have no right to refuse such opportunities, Kerobyan emphasized.
And what value can the RA government give to the enormous environmental pollution and damage that will take place in the heart of Armenia’s water resources for hundreds of years? Only the name Jermuk, is worth millions of dollars, and will be lost forever. The losses will be many times more, in the short and long term, than the short-term benefits of the Amulsar project for Armenia.
Vahan Kerobyan – Mining is not a priority sector, and we are not trying to exploit the subsoil, we have a copper smelter project.
In that case, why are alternative projects not proposed, planned and evaluated for that surrounding area, such as tourism, the development and expansion of Jermuk mineral water business worldwide, making Jermuk one of the best health centers in the world, the development of agriculture, and keeping the water quality and levels of Lake Sevan in good condition without negatively affecting the Arpa-Sevan tunnel, construction of residential buildings for Diaspora Armenian families and tourists, etc. It seems that your imagination is only focused on the short-term profit of a few people and not on the future of Armenia and its people.
Apart from other economic effects of Amulsar operation, budget revenues will increase by 30-40 billion drams annually. One of the most important motivations for the operation of the Amulsar mine is to strengthen Armenia’s security, the Minister of Economy emphasized.
Economic growth can be improved in other areas as indicated above, through better investment choices as well as better governance. The best way to strengthen Armenia’s security is to have a powerful army and reliable partners. If you can’t protect Armenia, you want a mining company and investment companies to do your job?
The interview of attorney Nazeli Vardanyan below is a good answer to the economy minister. (Google translated from Armenian)
Who will guarantee that the enemy will not bomb again the cyanide platform around Amulsar? Vardanyan
Inadequate studies by Lydian
Lydian and the RA government signed a contract in 2012, and in April 2016, the Ministry of Nature Protection gave a positive conclusion to start the construction of the Amulsar project.
http://www.minenergy.am/storage/files/pages/pg_6682404060481_245.pdf Լիդիանի եւ ՀՀ կառավարության միջեւ կնքված պայմանագրի պատճենը 2012 թվականին:
http://bit.ly/2Qth8S2 Բնապահպանության նախարարության դրական եզրակացության հաստատման նամակը Լիդյանին 2016 թվականի ապրիլի 29-ին։
However, this Lydian technical report https://bit.ly/3KNSRke published on March 30 2017, was produced after a contract has already been signed with the Armenian government in 2012 and 2016, and it says that additional studies are needed for the very important geochemistry, water treatment and water balance studies without which no mine can be permitted and operated anywhere (see page 397).
Those substantive studies were Lydian’s responsibility and should have been completed by Lydian before applying for the permit and signing the contract, not after.
Missing elements and underestimation of risks in this updated 2019 Lydian technical report are presented by us here: https://bit.ly/3K58Ppr. Neither the 2017 Lydian document https://bit.ly/3KNSRke page 397 nor the 2019 document https://bit.ly/3YclbQI page 27-3 indicate that Lydian have started and completed their geochemistry, water treatment and water balance studies. These studies are fundamental requirement for the design and operation of any mine anywhere in the world, that has not been completed until end of 2019 at least.
Without a finalized well-defined evaluation of the geochemistry, water treatment and water balance plans, with all the guarantees, no mine can get a permit and operate, meet international standards and be qualified to do any mining anywhere. Does the RA government have such detailed information from Lydian? Is that information available for public review? If not, on what basis was Lydian allowed to restart the Amulsar project in February 2023?
It is a known fact that any contractual agreement can be put on hold or cancelled until all additional studies are finalized, completed and approved. Any work and expenses incurred by Lydian in Amulsar prior to finalized documentation and final approval can become the responsibility of Lydian, not the Armenian government.
After reviewing the above, I hope that you seriously think about this project and reconsider your decision. Be transparent and present to the public all the economic, environmental, technical and contractual reasons for your decision to restart the Amulsar gold mine project and discuss with Armenian environmental representatives and scientists. This project has a direct negative impact on the future of Armenia. The losses and negative consequences will be far greater than the gains, for which you alone can be held responsible. Your government came to power to correct the mistakes of the past. We see however the same mistakes are continuing.
The Amulsar project is a hazardous chemicals and waste storage and operating facility in the heart of water resources of Armenia by a company with NO prior experience in mining anywhere in the world and little capital. It has no place in Armenia.
Armenia is our ONLY homeland and is NOT for sale!!
Chemical/Environmental Engineer, MS
2947 Honolulu Avenue, Unit B
Glendale, CA 91214
- https://earthworks.org/issues/acid-mine-drainage/ Acid Mine Drainage
- https://www.inap.com.au/acid-drainage/ Acid and Metalliferous Drainage
- https://www.youtube.com/watch?v=bjAUm_0wf9s Acid pollutes South Africa lakes
- https://earthworks.org/assets/uploads/2018/12/55-S.R.-Jenning-et-al.-2008.-Acid-Mine-Drainage-and-Effects-on-Fish-Health-and-Ecology-A-Review.pdf Acid Mine Drainage and Effects onFish Health and Ecology: A Review
- https://www.fidh.org/IMG/pdf/armenia_report_ar.pdf ԱՄՈՒԼՍԱՐ. ՄԱՐԴՈՒ ԻՐԱՎՈՒՆՔՆԵՐԻ ԽԱԽՏՈՒՄՆԵՐՆ ՈՒ ԲՆԱՊԱՀՊԱՆԱԿԱՆ ԱՆՓՈՒԹՈՒԹՅՈՒՆԸ ՈՍԿՈՒ ՈՐՈՆՈՒՄՆԵՐՈՒՄ
- https://bankwatch.org/project/amulsar-gold-mine-armenia Amulsar gold mine, Armenia
- https://www.opendemocracy.net/en/odr/armenia-amulsar-lydian-gold-mine-uk-russia-edb-bank/ The UK spent years lobbying for this Armenian goldmine. Now Russia is funding it
- https://eurasianet.org/armenia-restarts-controversial-gold-mine Armenia restarts controversial gold mine
- https://hetq.am/hy/article/153666 ՀԿ-ների հայտարարությունը Ամուլսարի հանքավայրի շահագործման վերաբերյալ
- https://www.facebook.com/groups/581255065636772/posts/1680240525738215/ ԴԵՄ ԵՄ ԱՄՈՒԼՍԱՐՈՒՄ ՀԱՆՔԱՐԴՅՈՒՆԱԲԵՐՈՒԹՅԱՆԸ
- https://www.youtube.com/watch?v=IVLT7nek6Mo Ամուլսարի հանքը շահագործելու նոր փորձ. հաշվարկվա՞ծ են բնապահպանական, անվտանգային ռիսկերը․
- https://www.azatutyun.am/a/32304021.html Ամուլսարի հանքավայրի գործարքից հետո բնապահպանների մտահոգությունները խորացել են