Ministry Rejects Lydian's Water Use Application

The Armenian Environmental Front reports: "The ministry has rejected Lydian's water use application based on our protest, in which they sought the right to extract 41.3 liters per second from the Arpa River for operations in Amulsar.

Amulsar is a mountain:

We present the objections of the Armenian Environmental Front that were sent to the minister, based on which we believe this application should be rejected:

1. The following requirement specified in the government's decision 218-N of 2003 is not substantiated and essentially not fulfilled: "The water extraction regime by months should be justified by the ecological discharge of the water resources and the water demand of other users in that area." Above the proposed water extraction point, the Kechut Reservoir has been constructed, which plays a regulatory role and completely alters the natural flow and discharge of the river. There has been no updated data since 1994 regarding the amount of water released from the reservoir by month, and there are no data on the low water months since 1989. Without these, it is impossible to make accurate hydrological calculations and obtain reliable data, as the amount of water in the riverbed is regulated by human intervention, not by natural conditions. Even prior to 1994, the existing data show that during low water months, very little water remains in the Arpa River after the Kechut Reservoir, and considering the significant climatic changes over the past 30 years and the decrease in surface water flows in Armenia, it has diminished even further. The previous water use application submitted by this company for the section below the Kechut Reservoir was rejected by the Minister of Environment on June 17, 2019, because only the ecological discharge of the Arpa River is available in that section. This application has again submitted a water extraction request for a point where only the ecological discharge of the Arpa River is present, and naturally, the application must be rejected on the same legal grounds as in the previous case.

Additionally, there are other water users both above and below the proposed water extraction point (domestic use, HPPs, irrigation, fish farming, etc.), about which no data were provided in the project. It is possible that this water extraction will impact other users, consequently altering the overall cumulative impact on the Arpa River, which has not been assessed or calculated at all. In the absence of all this information, the application cannot be approved, as the baseline data is insufficient to draw accurate conclusions and make a substantiated decision.

2. According to table 2 in the decision on approving the management plan and priority measures for effective management of the Ararat Basin for the years 2016-2021, dated March 31, 2016, the river flow in the Arpa basin was 679.8 million cubic meters in 2014, while it is estimated to be 648.7 million cubic meters for 2021 and 564.2 million cubic meters for 2040. This means that under the projected climate change conditions, the river flow in the Arpa basin will decrease by approximately 4.6% or 31.1 million cubic meters by 2021 and by 17% or 115.6 million cubic meters by 2040. There is no mention of this in the proposal, and it is clear that these indicators on the expected changes in water extraction were not taken into account or calculated when preparing the draft permission for the water extraction of 41.3 liters per second.

3. According to table 3 in the aforementioned decision, for the years 2019-2021, the industrial water use in the Arpa River basin will amount to only 0.08-0.09 million cubic meters per year, while according to the application submitted by Lydian Armenia, the annual water demand will be 1.284 million cubic meters. Therefore, the application should be rejected, as it contradicts the government's decision on the management plan for the Ararat Basin for 2016-2021.

4. While the company claims that it will only extract water, which will then be used in a closed-loop system, ultimately evaporating, and there will be no discharge through other natural waterways, we have grounds not to trust this information based on at least the following two facts:

(a) In a response to a query from the Environmental and Mining Inspection Body on November 2, 2018, it was noted that the inspection revealed and the company admitted that serious qualitative changes occurred in the waters generated during rainfalls in the mining area of Lydian Armenia on June 11, 2018, which polluted the Arpa River, resulting in the death of fish in the fish farming facility operating in that area (read more and watch videos at this link: http://www.armecofront.net/amulsar/arpa-river/). Attached to our letter is also the response of the inspection authority and Lydian's explanation regarding this issue, along with a photo showing the kind of "ultra-modern" system the company attempted to use to address this issue (you can view it in the video linked here: https://www.facebook.com/100010197097701/videos/645542182462346). We present these facts not to push for any actions from you, but to clarify what is written in the proposals and what is actually happening in reality. This means that the company claiming that there will be no discharge of contaminated waters as a result of its operations has already polluted the Arpa River twice during the construction phase, causing serious ecological negative repercussions. One can only imagine what might occur after the commencement of large-scale exploitation in Amulsar.

(b) The study by ELARD-TRC experts states that the volumes of water evaporation are overestimated in Lydian's EIA, which is also confirmed by the document from the Ministry of Environment to the Government dated September 5, 2019. Furthermore, the conclusions of the ELARD-TRC experts confirm that the baseline data mentioned in the EIA are largely incomplete and unreliable, the calculations of the water balance are not dependable, only the water systems of the open-pit area have been studied, and there has been no study in the tailings storage facility (TSF) and adjacent areas. The fate of the water used and circulated in the TSF for 10 years is not described, and it is unknown how the accumulated tailings, containing highly hazardous chemicals (sodium cyanide, sulfuric acid, etc.), dangerous heavy metals, as well as other highly hazardous chemical compounds resulting from chemical reactions (like thiosulfate), will be cleaned and released into the Arpa River or its tributaries. It is stated in the proposal that these will be cleaned and discharged, but there is no description of either the cleaning method, the type and design of the facility, or the volumes of water needed for this purpose and the qualitative composition of the discharged waters. It should be noted that one of the left bank tributaries of the Arpa River crosses through the central part of the TSF, which is not described, and its water balance and the potential impact of the company's operations on that water flow and consequently on the Arpa River have not been assessed. All these facts prove that there will be discharges into the Arpa River, and the assertion that this can be excluded does not correspond to reality, and naturally, without a proper assessment of this impact, it is not appropriate to grant this company new water use permits.

5. Lastly and most importantly, on December 5, 2019, the overwhelming majority of the adult population of the Jermuk community, including residents of Jermuk city, Kechut, Gndevaz, Her-Her, and Karmrashan villages, exercised their right of direct democracy and submitted a collective petition with around 3000 signatures to the Jermuk community council and leadership, presenting their vision for the economic development of their region and demanding that metallic mining be prohibited in the region and promote the development of a green ecotourism economy. The enlarged community council of Jermuk decided on December 18, 2018, to approve the proposal submitted by the community residents in their collective petition that called for turning the Jermuk community into an eco-economic area and prohibiting metallic mining in the community. This means that the majority of the affected community and their elected council oppose any metallic mining projects in their administrative territory. The ministry should also reject this water use application for this reason, as its consequences could potentially adversely affect the health, life, socio-economic conditions, and environmental quality of the citizens of Armenia living in the affected area due to the exploitation of metallic mines. This is their fundamental right, which they presented and exercised through all possible means, and any decision or granting of permits that ignores this cannot be legal and will lead to new confrontations and resistance from the community and citizens of Armenia.

"Armenian Environmental Front" voluntary civic initiative