ELARD experts: EIA and the 2016 project are insufficient for the safe  operation of the Amulsar gold mine

ArmInfo. The Armenian government got acquainted with the expert opinion of ELARD on the Amulsar project, and today has encountered problems in connection with the  interpretation of the document. With these words, the Prime Minister  of Armenia Nikol Pashinyan began his speech on August 29 at a Skype  conference with experts of the consulting company Earth link &  Advanced Resources Development (ELARD).

According to the prime minister, "the difficulties of a single  interpretation" are due to the fact that the text of the conclusion  contains numerous omissions, the necessary data are missing, but this  is not limited to the list of uncertainties. Nevertheless, as the  head of government pointed out, the impression is created that the  environmental risks of developing the Amulsar mine are manageable.  "Do we understand correctly that, in spite of the fact that in its  conclusion ELARD fixes a number of violations, omissions,  shortcomings in the Amulsar project, the generalized conclusion of  the company is that when applying 16 mitigation measures according to  the formula 10 plus 6, environmental risks will become manageable?  What will happen to water, air, soil and biodiversity in the case of  the development of the mine? ", the prime minister asked.

"Provided that the mine is developed properly and shut down  appropriately, as well as that the risk mitigation measures that are  complemented by the general and special Lydian activities are  properly implemented, there will be no damage to the Armenian water  basin," said Ricardo Khoury, environmental engineer and managing  partner at ELARD. At the same time, as the expert noted, all this  should be the result of proper planning, monitoring and subsequent  competent implementation. Only then, according to ELARD, should  environmental risks be managed in the immediate vicinity of the mine.

In response, Nikol Pashinyan remarked: "perhaps this is professional  slang, but when you say  "if, then, in the case of" we have problems  evaluating the meaning of what was said." The Prime Minister asked to  clarify whether the words "should become manageable" mean the minimum  degree of pollution of Armenia's water resources, greater or complete  absence of these risks.

According to an ELARD expert, "certain uncertainty" in his words is  related to the chemical composition of water. Again, as Khoury  pointed out, if the measures proposed by the company are implemented,  then the possible negative impact can be managed in such a way as to  avoid a negative impact on the country's water basin. "But all this  must be confirmed by a new assessment, that is, a new impact  assessment must be carried out with appropriate input data to confirm  this statement," he said.

In order to clarify what was said, the head of government noted: "Is  it possible to conclude that ELARD is not sure that under the  conditions offered by Lydian, Armenia will not ensure compliance with  the country's water resources - that is, the purity of water, which  is why you propose additional measures in order to be more confident?"

"This is a professional statement based on our experience," said an  ELARD expert. According to him, in fact, the measures proposed by  Lydian are inferior, and in order to bring them to full value, there  is a need to review the EIA (Environmental Impact Assessment) and  only develop new mitigation measures based on the new EIA .

After this series of "certain uncertainties", the Minister of the  Environment Erik Grigoryan had a question:  "Actually, who proposed  to draw up the Memorandum, since the work delegated by ELARD did not  require proposals and, therefore, can it be argued that based on the  existing EIA can not operate a mine. "

As the coordinator of the ELARD program explained, the Armenian  government ordered to identify project gaps. But there was an  additional mandate - to submit proposals that could potentially be  considered acceptable in order to make the impact of risks  manageable.

After what was said, Nikol Pashinyan became interested, "in what and  where did this order of the government appear." Upon reflection, the  ELARD expert team stated that they would answer the question after  clarifying the deadlines for the official request for an additional  order. Then the team's leading hydrogeologist Nidal Rabahi recalled  that the request had been voiced during the visit of the second  mission to Armenia. Further, the request was supported by an email  from the customer of the project - the Investigative Committee. It  was through the UK, as he noted, that ELARD contacted state bodies  and research institutes of Armenia. According to him, in Armenia they  asked the ELARD team whether the operation of the mine is possible,  taking into account all the omissions, and without harm to the  environment. "The request was not clearly recorded in our  instruction, but we identified them as a concept already in the  Memorandum," the expert explained. Pashinyan asked forwarding the IC  email with the corresponding additional instruction to the RA  government apparatus.

The Minister of the Environment, in turn, inquired whether ELARD  considers the Lydian EIA of 2016 sufficient to start work at the  mine. In addition, risk mitigation measures should be implemented  today or after 5 years, he asked.

"The ELARD team concluded that the 2016 EIA and project are not  sufficient for the safe development of the mine," said the program  coordinator. According to him, this position of the expert group is  documented in the appraisal report. According to ELARD, Lydian should  update the EIA in order to confirm mitigation measures before experts  express their position. The team's leading hydrogeologist, in turn,  noted that mitigation measures should be applied after 6 months or a  year, two, but not after 5 years.

In general, as ELARD experts noted, the data provided by Lydian was  inferior, modeling was ineffective.  "So much so that we could not  find a correlation of some figures. EIA is undeniably inferior and  not trustworthy," concluded ELARD.

To recall, the ELARD expert opinion on the Amulsar project cost the  Armenian taxpayer $ 396 thousand.  Lydian Armenia is a subsidiary of  British Lydian International. The total cost of the Amulsar project  is $ 370 million. The terms of mine development will be 10 years and  4 months, with an average of 200 thousand ounces of gold being mined  annually. Amulsar mine is the second largest reserves in Armenia.   According to the company, the deposit contains about 73733 kg of gold  with an average grade of 0.78 g per ton, as well as 294.367 tons of  silver with an average grade of 9.29 g per ton.