NGOs' Statement on the Exploitation of the Amulsar Mine

A number of NGOs have issued a statement regarding the exploitation of the Amulsar mine. We present it below:

On February 22, 2023, the Government signed a trilateral memorandum of understanding with the Eurasian Development Bank and Lydian Armenia LLC to resume the exploitation of the gold-bearing quartzite mine at Amulsar.

Who are the real beneficiaries of Lydian Armenia, according to the company’s declaration?

We, the undersigned representatives of organizations and individuals, express our deep disappointment and dissatisfaction regarding the Armenian government's illegal, short-sighted, irresponsible, risky decision with potential dangers for the state concerning the mining at Amulsar.

In planning to restart the Amulsar project, the Armenian government has disregarded Azerbaijan's aggressive actions. On September 13, 2022, Azerbaijan bombed the town of Jermuk. According to the Amulsar project, tens of thousands of tons of hazardous toxic chemicals and explosives, which will remain for hundreds of years, are to be accumulated and utilized near Jermuk. This poses a danger, not only to Jermuk but also to Lake Sevan, the entire Vayots Dzor, Syunik, and Ararat regions due to the pollution of the Arpa and Vorotan river basins, as well as Gegharkunik province due to the inflow of polluted waters from Arpa-Sevan.

The claims that the implementation of the Amulsar project and the attraction of international investments are guarantees of security are unfounded and manipulative in nature. The Sotk gold mine area is regularly targeted. In fact, international investments in the case of Sotk failed to deter Azerbaijan’s military ambitions. There is no guarantee that the same scenario will not repeat in the case of the Amulsar project, making Armenian territories even more susceptible to targeting.

The loss of Jermuk city as an internationally significant health resort has not been considered. Jermuk will turn into a laborer’s village, its native residents will emigrate, and mine workers will leave the area after the mining operation ends.

Involving the Eurasian Development Bank for financing the Amulsar project has not assessed the economic and political risks for the Republic of Armenia under Western sanctions against Russia. The bank's other major shareholders, Kazakhstan and Belarus, expressed pro-Azerbaijani positions during the Armenian-Azerbaijani war. Engaging in a transaction with a bank that has such shareholders poses an immediate threat to Armenia’s security.

No comprehensive environmental impact assessment has been conducted, nor have the findings and conclusions from the studies conducted by international companies ELARD and TRC in 2019 — for which the state budget paid $454,000 — been taken into account.

The negative impact on water resources such as Lake Sevan, the Arpa and Vorotan river basins, the Spandaryan and Kechut reservoirs, and groundwater due to acid drainage resulting in long-term pollution of surface and underground waters has been overlooked.

The risks associated with radioactive elements like uranium, thorium, and radon present in the Amulsar mine, along with the environmental pollution caused by the enormous volumes of toxic particles resulting from mining operations, have been ignored. The risks related to the use of cyanide technology, which is banned in several countries, have also been disregarded.

The potential negative impact on “Jermuk” mineral water, as well as the international commitments regarding biodiversity conservation bound by the Bern Convention, have not been considered.

The Minister of Health has declared that the resumption of the Amulsar project is not a health hazard and has passed the corresponding assessments. This does not correspond to reality as there were no proper assessments conducted during the four stages of environmental impact assessment for the Amulsar project, due to the absence of appropriate methodology.

The long-standing resistance of affected communities and the public against the Amulsar project has not been taken into account. In the autumn of 2018, around 3,000 residents of the enlarged community of Jermuk expressed their opposition to metallic mining by signing a public petition.

The previous practices of Lydian Armenia LLC, including illegalities and the use of violence against citizens, and the judicial persecution of citizens, have been ignored or not evaluated, once again entrusting public resources to a company registered in an offshore zone with unknown owners and facing a financial crisis.

Instead of adopting a policy to revive the once-thriving and now border-adjacent health resort of Jermuk, the government prefers, through the Amulsar exploitation project, to ultimately sacrifice Jermuk and its socio-economic established system for a few billion drams that will temporarily enter the state budget and the enrichment of several questionable offshore companies through the 10-11 years of exploitation of the Amulsar mine.

Given the uncontrollable risks of the Amulsar project, we oppose its implementation.

We demand from the President of the Republic of Armenia to:

• Ensure adherence to the Constitution and international norms, and declare an impartial stance regarding the economic, environmental, social, and security risks posed to Armenia by the implementation of the Amulsar project, guided solely by public and national interests.
• Support the community in fighting against a project dangerous for the Republic of Armenia, preventing violations of the Armenian Constitution, and ensuring national security and environmental protection.

From the Ministry of Territorial Administration and Infrastructure of the Republic of Armenia:

• Terminate the mining license granted to Lydian Armenia LLC, which was extended due to the unconstitutional and anti-democratic law on “Amendments and Changes to the Mining Code” adopted on May 25, 2022.
• Officially publish information regarding uranium reserves in Amulsar.

From the Ministry of Health of the Republic of Armenia:

• Publish the results of all assessments conducted by the Ministry of Health regarding the impact of the Amulsar project and other mines on human health.

From the Ministry of Economy of the Republic of Armenia:

• Publish the trilateral memorandum signed between the Ministry of Economy of Armenia, the Eurasian Development Bank, and Lydian Armenia LLC, as well as the contract regarding the sale of part of Lydian Armenia LLC shares to the Government of Armenia.

From the Ministry of Environment of the Republic of Armenia:

• Declare void the environmental assessment conclusion given in 2016 for the Amulsar project, taking into account the inadequately assessed risks and the newly emerged ecological factors.

From the Prosecutor General of Armenia:

• Initiate a criminal case and disclose all those responsible for the shortcomings in the environmental impact assessment and examination that laid the groundwork for the outrageous advancement of the problematic Amulsar project.

From the Government of the Republic of Armenia:

• Reject the project for the exploitation of the Amulsar mine until financing has been secured, investments made, and the Republic of Armenia has not assumed the financial burden of compensating losses.

From international organizations accredited in Armenia:

• Support the realization of human rights and democratic processes in Armenia for the safety of the Republic of Armenia and its citizens.

Signatures:

Transparency International Anti-Corruption Center
“Center for Community Mobilization and Support” NGO
“Environmental Rights” NGO
“Democratic Platform” Foundation
“Human Rights Research Center” NGO
“EcoLur” Information NGO
“Green Armenia” Environmental Educational NGO
“Forest of Armenia” Environmental NGO
Armenian Environmental Front Volunteer Initiative