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Lena Nazaryan

Ministry Decision Contradicts 77 Articles of the Law

At a press conference on February 16, Armenian Copper Program (ACP) executive director Gagik Arzumanyan said that the area of the Teghut forest to be cleared would come to 357.16 hectares, with a timber yield of 57.7 thousand cubic meters, in case the copper and molybdenum reserves in the Lori provincial region were to be mined. These calculations cover the damage to be done by 25 years of mining, coming to a monetary sum of 2 billion drams.

The Ministry of Nature Protection of Armenia has already given its approval to a project outlining eight years of mining, a written proposal for which included an assessment of the effects to the environment caused by the mining activity. NGOs involved in environmental conservation insisted that this decision infringed upon 14 articles of the law on environmental impact assessment. According to Srbuhi Harutyunyan, President of the Socio-Ecological Association, this decision would lead to the infringement of 77 articles in different laws.

During the press conference, the ACP executive director urged everyone to forget this “negligible” concern and concentrate on preventing illegal logging, the volume of which greatly surpasses the deforestation proposed by the outlined project. As if through an agreed script, a similar suggestion was made by Minister for Nature Protection Vardan Ayvazyan, at a separate press conference. “Only 60 thousand cubic meters of wood will be cleared. According to a study by the World Bank, illegal logging inArmenia comes to an annual volume of 600-700 thousand cubic meters of wood. These are more serious numbers,” Vardan Ayvazyan rationalized. The minister noted that his stand on this issue was unequivocal.

Environmentalists claim that such comparisons are absurd and pointless. Mining would destroy not just the trees, but other components of the immediate environment as well – the rivers, soil, air, the diverse flora and fauna would be unable to survive. In such conditions, the environment would be unable to recover.

“As an expert, I say with conviction that cutting down even a few trees on slopes such as these would lead to soil erosion. After the mining is done, we would have a pit in northernArmeniaaround 400-500 meters deep, and the territory would be considered one of increasing degradation. What does this have to do with illegal logging?” asked Srbuhi Harutyunyan.

Environmental NGOs note that the project is flawed and all major damage has been calculated for only eight years of exploitation. In the opinion of Greens Union president Hakob Sanasaryan, the project activities have been intentionally presented only in part, which is unprecedented and illegal. Company executive director Gagik Arzumanyan explained that this was because there were consequences that could not be predicted at this point. “Yes, the project does not have all the information for the period of 25 years. In the project, we have tried to show those indicators which are predictable for a period of eight years of mining,” Arzumanyan said.

“The calculations presented over 25 years include the ore, mine rock, industrial and other waste, utilized water as well as the volume of extracted copper, molybdenum and other metals. But the damage to the environment is only presented over 8 years. By presenting the project bit by bit the company is seeking to cover up the real amount of damage to the environment. If the company gains permission for the first stage of mining and work begins, then the process will become unstoppable,” said Greens Union president Hakob Sanasaryan.

In Sanasaryan's opinion, even the deforestation of that abundant forest cannot compare to the potential damage caused by the mining activity. “The wastes generated during production will contain heavy metals and other hazardous material, which would doubtless end up in the soil, water and air. The sum of money presented as financial losses by the company is a joke,” said Sanasaryan. Although the company admitted that the pear trees there are a rare variety, the financial loss sustained by cutting down a pear tree with a 36 cm thick trunk was assessed as only one thousand drams.

The most serious damage, according to environmentalists, is posed by the tailings.

Copper and molybdenum production occurs basically in the following way. Explosive substances are used to separates shards of ore, which are then powdered. In the extraction plant, this powder is mixed with water and chemical reagents. Water bubbles separate the powder which contains copper and molybdenum. This foam is considered to carry the metals and is collected. The remaining liquid will be poured out to a tailing storage facility through pipes. The tailing structures are planned to be built around 3.5 km away from the plant, in the gorge of the river Kharatanots, with a surface area of roughly 110 hectares. The volume of the entire tailing storage facility, calculated at an annual production level of 7 tons, comes to 552 million cubic meters after 25 years (there is expected to be 1000 million tons of waste in the gorge after ore extraction). The project authors could propose only one thing in this case – that 30-50 cm of soil cover be placed to cover the powder in the gorge after ore extraction.

Hakob Sanasaryan was convinced that the tailing storage facility, built on a steep slope, would be unable to bear the weight of million of tons of waste. In his opinion, guarantees of the stability of the wall and clay layers were not well founded and that mudslides and land collapse would most likely become regular occurrences there.

“In order to convince oneself and draw comparisons as to what state it will be in after mining, whoever is truly concerned with the conservation of this area can visit the Nahatak river gorge, which is in terrible condition due to the tailing storage facility there belonging to the Alaverdi Mining Plant. This reservoir does not exceed 1.5 million cubic meters,” said the Greens Union president.

In order to set up the tailing structure, it has been planned to change the course of theKharatanotsRiver. Environmentalists are also concerned with the fact that the new course will only be maintained for 25 years, after which there is no guarantee that the company will continue to renovate the artificial flow.

ACP company executive director Gagik Arzumanyan gave assurances that the project did not plan to relocate the residents of the Teghut and Singh villages. However, those villages are located 4 and 6 km respectively from the mine site. According to Greens Union president Hakob Sanasaryan, the company did not need to present the relocation of those populations as part of their plan because those residents would be forced to leave themselves.

“25 years later the place would be a desert. The tailings and wastes, containing heavy metals, would penetrate the soil, water and air, causing disease, ruining the produce and sharply reducing soil fertility. Naturally, the people there would then be forced to leave,” said Sanasaryan.

ACP has already purchased from the villagers half of the 200-hectare territory required for the exploitation of the mine. In order to build the structures required for production and exploitation of the mine a total of around 670 hectares will be required, 510 hectares of which have forest cover.

The mining project presented by the company which has already received the Ministry's approval has a number of inconsistencies which, according to environmentalists, might cause serious doubts regarding the integrity and validity of the whole study.

“Above a table describing insect life, the title reads ‘Insects Registered inTeghutVillage,North-East Dilijan' with the author stated as entomologist Mark Kalashyan. In a telephone conversation with me, Mark Kalashyan said that in 2005, on a contract with the World Bank, he had studied insect life in the forests near thevillageofTeghutin the Dilijan region. This site is tens of kilometers away from thevillageofTeghutin the Tumanyan region. He also said that he hadn't been in the forests of the Teghut village within the Tumanyan region of the Lori province. Thus, they have used data from the forests of Dilijan and attributed it to the forests of Lori. This is obvious fraud.

“Or, another of the tables in the plan lists the species of tree and the quantities in which they will be cut down. The text mentions that 127,000 trees will be cut down, but when I added up the numbers in the tables myself, it came to 170,833. Of course, compared to the legal infringements conducted by the company while writing up the plan the inconsistencies in the number of trees or the insects seem trivial. However, these and perhaps other inconsistencies that have gone unnoticed give grounds to doubt the company and their promises. The Armenian Ministry of Nature Protection has approved of that project. One can say that as far as their methods regarding the law go, the company and the Ministry have been working in harmony,” said Hakob Sansaryan. Before any activity can be realized, it is necessary to obtain a series of agreements and permits (including an Armenian Government decision changing the utilization status of that land, i.e. the territory which will be mined must be given the status of industrially significant land).

The reserves in the mine were confirmed in 1991. In 453.8 million tons of ore, the copper content was calculated as 0.355%, while the average molybdenum content was 0.021%. The site will be exploited as an open mine. According to the project presented by the company, during the first stage of exploitation (8 years), the production capacity of the mine will be an annual 7 million tons. During the first 8 years, a total of 158 hectares of forest (24.5 thousand cubic meters) would be logged.

“We now have the right to lodge a complaint in court against the Ministry's decision. We have this right through article 21 of the law on environmental impact assessment. We also plan to stage protests and other events to put a stop to this,” said Srbuhi Harutyunyan.

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