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GLOBAL GOLD MINING ARMENIA BRANCH
SECOND STATEMENT REGARDING FALSE CLAIMS BY SOME INDIVIDUAL
REPRESENTATIVES OF NGOs
DISCLOSURES
It has been for some time that some individual representatives of some
NGOs in Armenia continue to make deliberately unsubstantiated,
contradicting to facts and reality claims regarding the environmental
situation at Toukhmanuk mine, including through internet and letters
to various organizations and individuals.
Since November 2, 2012, the time when the Company transparently and
openly presented the construction project for its next tailings dam to
be constructed at Toukhmanuk property for public discussions, these
individual representatives (including, specifically, Silva Adamian,
representing Bird - Fanciers NGO, Hakop Sanasarian, representing
Armenian Greens Association, Artur Grigorian, representing Ecoright
NGO, and others), started posting claims that contradict the reality
regarding Toukhmanuk new tailings dam, specifically, and the
activities of Mego Gold in general, in the internet and media.
Deliberate, and often simply insulting statements and claims were
made, including, through selectively presenting, by falsely
misrepresenting and misinterpreting the different parts of the
Toukhmanuk new tailings dam construction project documents, often
twisting and forging the clear and undeniable facts and realities,
including through acting `unaware' about well known facts and
realities, for the purposes of a deliberate and smear propaganda
agasnt the Company's activities.
Thus, during November 2012, through some internet and media
publications, these individuals claimed, that (i) `Mego Gold is going
to contstruct a tailings dam with a territory of about 7 hectares',
(while, in fact, the territory of the tailings dam is only 1,53
hectares, according to presented project documents), (ii) due to Mego
Gold activities `no babies are born in Melikgyough anymore', or
`infant natality became almost zero', (while, in fact, only in 2012,
25 babies were born in Melikgyough, and 7 more babies were born since
January 2013 until now, i.e., infant natality rate in Melikgyough is
higher than average rate in Armenia by 1,7 times), (iii) due to
activities of Mego Gold `the cases of cancer disease multiplied in the
community', (while, in fact, during the activities of Mego Gold since
2008 only three cases of cancer was registered in the community, all
patients being older than the age of 75, i.e. only 0,26% of the
community, while the average rate in Armenia is 1%, and, for example,
another community with the same population in the same province,
Katnakhpyur, that has no mining property or any industrial activities
around, registered 18 cases of cancer, i.e., 6 times more than in
Melikgyough, during the same period), (iv) `there were numerous cases
of accidents at the tailings dam, and it collapsed', (while, in fact,
there were no accidents at tailings dam, and it never collapsed, there
were no such signals even from unofficial sources), (v) that `no one
knows about the mining plan', `the public is not being informed about
such plans', and, `only small amount of information was possible to
extract forcefully', (while, in fact, the mining plan, including the
open pit plan, treatment plant plan, and the tailings dam plan were
prepared, examined, including for environmental and health protection
aspects, filed and subjected to special expertise, including through
public hearings with participation of the representatives of the
community back in 2008, and these plans, along with all accompanying
documents, are available at the respective bodies and at the Company,
all publicly available, including pursuant to Armenian Law on Freedom
of Information), (vi) due to activities of Mego Gold `land fertility
declined multiple times', `villagers reap no harvest', `land fertility
dropped, fields are being destroyed and deserted', `huge damage is
caused to the community's agriculture', (while, in fact, the harvest
of oat as a general culture raised in the community during 2012 was
record high, for non - irrigational lands, amounting 25 metric
centners/ha, the potato harvest was also much higher than the average,
amounting 35 tonns/ha), (vii) due to activities of Mego Gold
`territory necessary for cattle breading dramatically declined',
(while, in fact, Mego Gold is using only industrial lands, Melikgyough
community agricultural lands territory amounts to 2,337.3 hectares,
vs. Mego Gold mining territory amounting to only 46,7 hectares, i.e.,
only 2% of territory compared to the community's agricultural lands),
(viii) that `drinking water is contaminated, because the tailings
infiltrate the irrigation water', `the quality of drinking and
irrigation water supplied to Melikgyough dramatically worsened),
(while, in fact, Mego Gold conducts permanent environmental monitoring
in and around Toukhmanuk property through an independent expert
organization, since 2006, such monitoring including some 23 elements,
including the metals, the results are disclosed by the expert
organization to the community, local government, state bodies, NGOs,
and also posted on the internet, during these 6 years of monitoring no
cases of any release of any element into the environment, including
into the drinking and irrigation water of Melikgyough, was recorded),
(ix) that `water generation and water supply systems are breached and
destroyed', that `it is impossible not to breach or destroy water
generation systems, since property exploited by the Company is the
part of such system of water generation and water supply', (while, in
fact, the territory of such water generation and water supply is
consisting of 80 to 100 square kilometers, comprising the most part of
the Tsakhunyats plato, while the mining territory of Mego Gold is only
0,46 square kilometers, i.e., only 0,46% or 0,57% of the whole water
generation and supply system, and all water generation and supply
systems are being preserved even in the mining territory of the
property).
Aside from these claims, there were also other, numerous, deliberately
false and fabricated claims, from the same individual representatives.
Generally, individuals making these claims are not only well aware
about the nature of their claims being false and fabricated. They are
also aware that the Company and Mego Gold are taking care and spend
big amount attention towards the environment, and that they never
breached any environmental rule or statute.
Besides these clams, the same individuals made public claims of simply
insulting and defamatory character against the Company and its
employees, publicly calling them `parorexia', `thief', `exploiter of
the poor', and other, publically called the community members`cowards'
and `corrupt', the community residents who disagreed with their
false statements as `traitors', and the fact of the community official
consent to construct of the new tailings dam as a `bargain'. The
offenders, presumably, are all educated, some with scientific titles,
all considering themselves as public representatives, while the norms
of civilized manners, and not this obscene behavior, shall be typical
to public or any of its representatives. One of the offenders, for
example, went so far in his own manipulation and twisting of the
reality, that publically accused the CEO of the Company, a descendant
of the generation escaping the Genocide and living in Diaspora, whose
track of record in international recognition of the Genocide is
evident and undeniable, in `intention to take part in the Genocide'.
Afterwards, in a clear attempt to `implement' the false and fabricated
claims already made deliberately and disseminated, Silva Adamyan, on
behalf of the Ecological Public Alliance, appealed to the Prime
Minister and the Minister of Environment of Armenia, and demanded to
`stop all the activities of Mego Gold', referencing to the same false
accusations made.
Considering that the deliberate manipulation and twisting the facts
and reality shall have a potential of causing damage to the reputation
of the same NGOs that these individuals are representing, and also
considering, that the same individuals shall be concerned about such
damaged reputation at the first place, the Company came up with a
public statement in January 31, 2012, pointing to factual evidence,
and called to refrain from damaging the reputation of the NGOs and the
public representatives, refrain from disseminating obscurantism and
considering the clear evidence and scientific substantiation instead,
refrain from insulting the Company, its employees and the community
residents, and offered a good faith cooperation with the Company in
its everyday work aimed at protection of the environment.
Instead of accepting the reasonable offer made by the Company which
would be acceptable to any true public representative, the same
individuals, without even trying to refute any of the evidence or
expert test results and scientific substantiation provided by the
Company, tried to continue disseminating the same false and fabricated
claims against the Company, through changing the ways of manipulation
only.
First, an attempt was made to accuse the Company as if the latter
`conceals' its mining plans and documents from the public.
Furthermore, these individuals, while acting as falsely unaware,
attempted to accuse the Company in `publically refuting' the presence
of metals in the tailings dam, accused the Company in concealing the
methodic by which the project documents were prepared', demanded
`expert information' (as if such information was not disclosed the
public), and, furthermore, claimed as if the information contained in
a scientific work that was published in 2010 (Sh. Khachatryan,
`Geological and chemical specifications of the Toukhmanuk Gold Mine')
contradicted the information provided by the Company, and further
claimed that the Company, its officers and specialists `deliberately
mislead the public, by concealing the content of the tailings to be
placed in the tailings dam and their potential effect on the health of
the residents of the community and the entire region'.
In fact, however, in November 27, 2012, the Company presented only the
construction project of its new tailings dam to be constructed for the
public hearings, including the environmental study for the
construction of the tailings dam. While, in fact, the Company
presented and implemented the public hearings for Toukhmanuk mining
plan back in April 21, 2006, in the community hall of Melikgyough
village, in presence of hundreds of attendees. For the purposes of
such hearings, the Toukhmanuk mining plan, including the open pit
plan, treatment plant plan, and the tailings dam construction plan
were presented and publically discussed, along with any and all
accompanying documents, analysis, and scientific reports, consisting
of hundreds of pages of documents. Community officials, residents,
public figures, intellectuals, National Assembly members, specialists,
NGO representatives, reporters, local clergy members, and others
simply interested in the Toukhmanuk project attended the hearings
(please see the pictures attached). The hearings took almost all day.
In the result, the detailed project documents, along with expert and
scientific substantiations, were filed to the Ministry of Environment,
along with the community's consent for the project to commence, and
for expert examination. In the result of the expert examination,
conducted in all detail and scrutiny, the Environmental Approval for
Toukhmanuk Mining Plan was issued. All the documents presented at the
hearings, then presented for the Approval, and even after the hearings
and such Approval, are publically available at the official bodies and
the Company, pursuant to Armenian Law on Freedom of Information.
Besides these open, transparent and public proceedings of 2008, the
Company prepared and filed the results of its massive geological
exploration of Toukhmanuk ore field in 2006, consisting of the result
of diamond drilling of 25,000 meters, surface and trench sampling, and
scientific report for this exploration. All these documents are also
publically available. In the result of the Company's scientific
research, the Toukhmanuk Pre Feasibility Study (including the
environmental impact study), the Toukhmanuk Metallurgical Reports
(four of them, for the years of 2008, 2009, and 2010), also the
Company's `Toukhmanuk Geological Exploration Report' for 2009, were
all prepared, and filed for approval of Toukhmanuk reserves at the
Ministry of Energy and Natural Resources. All these documents are
publically available, and the proceedings at the Ministry were all
open for public. In fact, the scientists (Sh. Khachaturyan), who,
according to the accusers, `revealed' the `concealed' information by
the Company, co - authored the Company's `Toukhmanuk Geologcial
Exploration Report', and the scientific work he published in 2010 is
just the brief version of the Company's 2006 Report.
One specific episode of attempts to falsely accuse the Company by
these individuals is typical: in their fabricated attempt to `reveal
the truth', one of this individuals, without notifying the Company or
inviting the Company to participate, and secretly from the Company,
initiated `sampling the tailings dam and the soils from the yards of
the villagers of Melikgyough', then falsely announced about`revealing
the concealed by the Company concentrations of some elements that
exceed the limits provided under the law', and placed the statements
in the internet, without analyzing, immediately.
For legal consideration, it is worth to mention, that Armenian law
(like the laws of other countries) does not provide `limits for
concentration of elements in the tailings'. Such statement is a mere
manipulation, and is aimed at misleading. The tailings are wastes,
they are neither eatable, nor drinkable, for the law to provide limits
of concentration of any elements in them. The waste is preserved in
the tailings dams, and isolated from the outside environment, just
because it is waste. Moreover, Armenian law considers the waste from
mining (tailings) as `non - dangerous' waste. This is a clear and
known fact.
The same individuals, by the way, repeatedly refused the Company's
offer to participate in the independent permanent environmental
monitoring, and even analyze the duplicates of the samples in
alternative laboratories, just to make sure that the results of the
monitoring are correct. The Company discovered only recently the
reasons for such refusal to participate, by the mentioned individuals.
Although the results of the lab assessments made by the representative
of NGO were not provided to the Company, the Company was able to
acquire them (see attached). According to the assessment made by one
of the labs of the Armenian National Academy of Science, the
concentration (mg/kg) of barium (BA) in the soil of the yards of
villagers exceeds the concentration of the same element in the
Company's tailings (waste) by up to 2,2 times, cobalt (Co) by 2,1
times , crome (Cr) by 2,3 times, copper (Co) by 1,8 times, nikel (Ni)
by 1,9 times, rubidium (Rb) by 1,4 times, tin (Sn) by 2,3 times,
stroncium (Sr) by 2,8 times, vanadium (V) by 2,3 times, zinc (Zn) by
15,2 times, circonium (Zr) by 2 times, iron (Fe) by 2 times, titan
(Ti) by 2 times.
According to this assessment, and the logic of concentration of
different elements, even if the Company tailings were not only
released (which is ruled out by the independent and permanent
environmental monitoring), but entirely replaced the soils (which is
impossible), the concentration of these elements would be much less
than those in the waste. It is also evident, that the Company waste is
much `cleaner', in consideration of the concentration of these
elements, than the soils of the villagers. If the concentration of
these elements in the soil was simply compared with the same
concentrations in the tailings, and given a simple analysis,
logically, the representatives should had thought of something else
than falsely accusing the Company in contaminating the soil.
Apparently, the villagers themselves told the representatives that
they are well aware, and were aware for a long time, of the
concentration of at least some of these elements in their soils even
before the Company activities began (during one of the meeting
organized by the representatives at the community, to which the
Company was not even invited), since back in soviet times large
amounts of different chemicals were widely used in the community
against rodents, and other chemicals as fertilizers, and even after
the soviet government's banning them, these chemicals were not removed
from the village, but buried in their soils instead, massively.
Fertilizers are still being used. Apparently, the representatives knew
about it, but choose to falsely accuse the Company instead, and even
disseminated a public statement claiming, as if, that the Company `is
refuting the results of the assessment' made by these
representatives. Instead, the Company is expecting that these
individual representatives themselves should refute their own
statements against the Company.
Moreover, understanding full well that their accusations against the
Company are entirely false and fabricated, the same representatives
organized different meetings at the Community, as if to discuss the
activity of the Company, but did not invite the Company or its
representatives to such meetings. During these meetings these
individual representatives are trying, through spreading a mere
obscurantism, provoke some individual residents to make false
statements against the Company purely for a smear propaganda purposes.
For example, during one of the meetings where the Company
representatives participated without being invited, an NGO
representative stated that the Company officers shall be `sentenced to
death by hanging' , not for harming the environment, but for just
mining the property, since mining is `evil', many other countries
banned mining at all and officially, as mining itself if harmful, but
encourage their companies mining in Armenia instead (such as Germany).
Company representatives witnessed during the same meeting, that a
specific person representing an NGO, would invite some individual
residents he personally knew out of the discussion room, coached them
what to say when back in the discussion room, while the other
individual representative would videotape in detail the resident's
yelling and simply cursing, and placing the video in the internet
later, as if a bright evidence of the communities `resistance'. This
behavior was not even being concealed, and no footages are placed in
the internet by these individual representatives, where the community
members not only disagree with their false accusation, but also oppose
them. As a result, artificially fabricated nature of the footages
placed in the internet by these individual representatives is
apparent.
This, indeed, is a disguised behavior. It is clear that some NGO
representatives apparently trying to put obstacles, and even stop the
activities of a company the record of which clearly provides that the
company not only proved its dedication to preventing any violations of
the environment, not only proved its dedication to social
responsibility, but also considered these issues as a top priority.
However, not only the false accusations against the Company don't
stop, but escalate instead, through dirty tactics.
Company's attempts to investigate such odd behavior resulted into sad
revelations that the Company is disclosing herein.
The Company was informed that some of these individual
representatives, apparently, applied to some international and local
sources asking for financing against environmental violations at
Toukhmanuk, often repeatedly and morbidly insisting. The Company was
also informed, that some international sources told these individual
representatives, that taking into account the transparent activities
of the Company, there are simply no evidence of any environmental
violations at Toukhmanuk, and there is an absolute absence of any
public awareness of such violations. Apparently, these individual
representatives understood the advice differently: public awareness
can be fabricated, and the evidence falsified. This is a simple soviet
approach, which does not lead to any results anymore.
The Company is still investigating the advice provided to these
individual representatives by the local sources to finance for
hindering or stopping the Company activities, however, the Company's
specific revelations currently available are also disturbing. It has
been for weeks, that one of these individual representatives, for
example, is posting in her personal facebook account (through opening
a special group) the materials posted in the internet and media a
while ago, for the purposes of smear propaganda initiated by a former
government official in the context of that official's corrupt demands
against the Company. This specific individual representative became so
exited, that even posted, and tried getting `likes' from facebook
audience, on the media reports about another company's activities with
the same name (Global Gold), in Kirgizia.
This behavior is extremely concerning, is harmful to the country, the
industry, the economy, facilitates the emigration - already a problem
for the country, is harmful for the reputation of NGOs, and shall be
stopped immediately. Representing group or individual interest by
individual representatives of NGOs, and their copying corrupt
officials' behavior cannot be allowed. Armenia deserves to have
environmental NGO truly dedicated at protection of the environment of
the country.
In light of these realities, the Company is hereby requesting these
individual representatives to disclose the international and local
sources their applied for their activities regarding Toukhmanuk mine,
and the purposes and conditions for such activities.
The Company will continue working transparently and openly, including
for the protection of the environment. As always, we are open for any
discussion that is aimed at serving interests of the communities of
the Company's operations.
Global Gold Mining, LLC Armenia Branch
- Social
News from Armenia and Diaspora - Noyan Tapan
GLOBAL GOLD MINING ARMENIA BRANCH
SECOND STATEMENT REGARDING FALSE CLAIMS BY SOME INDIVIDUAL
REPRESENTATIVES OF NGOs
DISCLOSURES
It has been for some time that some individual representatives of some
NGOs in Armenia continue to make deliberately unsubstantiated,
contradicting to facts and reality claims regarding the environmental
situation at Toukhmanuk mine, including through internet and letters
to various organizations and individuals.
Since November 2, 2012, the time when the Company transparently and
openly presented the construction project for its next tailings dam to
be constructed at Toukhmanuk property for public discussions, these
individual representatives (including, specifically, Silva Adamian,
representing Bird - Fanciers NGO, Hakop Sanasarian, representing
Armenian Greens Association, Artur Grigorian, representing Ecoright
NGO, and others), started posting claims that contradict the reality
regarding Toukhmanuk new tailings dam, specifically, and the
activities of Mego Gold in general, in the internet and media.
Deliberate, and often simply insulting statements and claims were
made, including, through selectively presenting, by falsely
misrepresenting and misinterpreting the different parts of the
Toukhmanuk new tailings dam construction project documents, often
twisting and forging the clear and undeniable facts and realities,
including through acting `unaware' about well known facts and
realities, for the purposes of a deliberate and smear propaganda
agasnt the Company's activities.
Thus, during November 2012, through some internet and media
publications, these individuals claimed, that (i) `Mego Gold is going
to contstruct a tailings dam with a territory of about 7 hectares',
(while, in fact, the territory of the tailings dam is only 1,53
hectares, according to presented project documents), (ii) due to Mego
Gold activities `no babies are born in Melikgyough anymore', or
`infant natality became almost zero', (while, in fact, only in 2012,
25 babies were born in Melikgyough, and 7 more babies were born since
January 2013 until now, i.e., infant natality rate in Melikgyough is
higher than average rate in Armenia by 1,7 times), (iii) due to
activities of Mego Gold `the cases of cancer disease multiplied in the
community', (while, in fact, during the activities of Mego Gold since
2008 only three cases of cancer was registered in the community, all
patients being older than the age of 75, i.e. only 0,26% of the
community, while the average rate in Armenia is 1%, and, for example,
another community with the same population in the same province,
Katnakhpyur, that has no mining property or any industrial activities
around, registered 18 cases of cancer, i.e., 6 times more than in
Melikgyough, during the same period), (iv) `there were numerous cases
of accidents at the tailings dam, and it collapsed', (while, in fact,
there were no accidents at tailings dam, and it never collapsed, there
were no such signals even from unofficial sources), (v) that `no one
knows about the mining plan', `the public is not being informed about
such plans', and, `only small amount of information was possible to
extract forcefully', (while, in fact, the mining plan, including the
open pit plan, treatment plant plan, and the tailings dam plan were
prepared, examined, including for environmental and health protection
aspects, filed and subjected to special expertise, including through
public hearings with participation of the representatives of the
community back in 2008, and these plans, along with all accompanying
documents, are available at the respective bodies and at the Company,
all publicly available, including pursuant to Armenian Law on Freedom
of Information), (vi) due to activities of Mego Gold `land fertility
declined multiple times', `villagers reap no harvest', `land fertility
dropped, fields are being destroyed and deserted', `huge damage is
caused to the community's agriculture', (while, in fact, the harvest
of oat as a general culture raised in the community during 2012 was
record high, for non - irrigational lands, amounting 25 metric
centners/ha, the potato harvest was also much higher than the average,
amounting 35 tonns/ha), (vii) due to activities of Mego Gold
`territory necessary for cattle breading dramatically declined',
(while, in fact, Mego Gold is using only industrial lands, Melikgyough
community agricultural lands territory amounts to 2,337.3 hectares,
vs. Mego Gold mining territory amounting to only 46,7 hectares, i.e.,
only 2% of territory compared to the community's agricultural lands),
(viii) that `drinking water is contaminated, because the tailings
infiltrate the irrigation water', `the quality of drinking and
irrigation water supplied to Melikgyough dramatically worsened),
(while, in fact, Mego Gold conducts permanent environmental monitoring
in and around Toukhmanuk property through an independent expert
organization, since 2006, such monitoring including some 23 elements,
including the metals, the results are disclosed by the expert
organization to the community, local government, state bodies, NGOs,
and also posted on the internet, during these 6 years of monitoring no
cases of any release of any element into the environment, including
into the drinking and irrigation water of Melikgyough, was recorded),
(ix) that `water generation and water supply systems are breached and
destroyed', that `it is impossible not to breach or destroy water
generation systems, since property exploited by the Company is the
part of such system of water generation and water supply', (while, in
fact, the territory of such water generation and water supply is
consisting of 80 to 100 square kilometers, comprising the most part of
the Tsakhunyats plato, while the mining territory of Mego Gold is only
0,46 square kilometers, i.e., only 0,46% or 0,57% of the whole water
generation and supply system, and all water generation and supply
systems are being preserved even in the mining territory of the
property).
Aside from these claims, there were also other, numerous, deliberately
false and fabricated claims, from the same individual representatives.
Generally, individuals making these claims are not only well aware
about the nature of their claims being false and fabricated. They are
also aware that the Company and Mego Gold are taking care and spend
big amount attention towards the environment, and that they never
breached any environmental rule or statute.
Besides these clams, the same individuals made public claims of simply
insulting and defamatory character against the Company and its
employees, publicly calling them `parorexia', `thief', `exploiter of
the poor', and other, publically called the community members`cowards'
and `corrupt', the community residents who disagreed with their
false statements as `traitors', and the fact of the community official
consent to construct of the new tailings dam as a `bargain'. The
offenders, presumably, are all educated, some with scientific titles,
all considering themselves as public representatives, while the norms
of civilized manners, and not this obscene behavior, shall be typical
to public or any of its representatives. One of the offenders, for
example, went so far in his own manipulation and twisting of the
reality, that publically accused the CEO of the Company, a descendant
of the generation escaping the Genocide and living in Diaspora, whose
track of record in international recognition of the Genocide is
evident and undeniable, in `intention to take part in the Genocide'.
Afterwards, in a clear attempt to `implement' the false and fabricated
claims already made deliberately and disseminated, Silva Adamyan, on
behalf of the Ecological Public Alliance, appealed to the Prime
Minister and the Minister of Environment of Armenia, and demanded to
`stop all the activities of Mego Gold', referencing to the same false
accusations made.
Considering that the deliberate manipulation and twisting the facts
and reality shall have a potential of causing damage to the reputation
of the same NGOs that these individuals are representing, and also
considering, that the same individuals shall be concerned about such
damaged reputation at the first place, the Company came up with a
public statement in January 31, 2012, pointing to factual evidence,
and called to refrain from damaging the reputation of the NGOs and the
public representatives, refrain from disseminating obscurantism and
considering the clear evidence and scientific substantiation instead,
refrain from insulting the Company, its employees and the community
residents, and offered a good faith cooperation with the Company in
its everyday work aimed at protection of the environment.
Instead of accepting the reasonable offer made by the Company which
would be acceptable to any true public representative, the same
individuals, without even trying to refute any of the evidence or
expert test results and scientific substantiation provided by the
Company, tried to continue disseminating the same false and fabricated
claims against the Company, through changing the ways of manipulation
only.
First, an attempt was made to accuse the Company as if the latter
`conceals' its mining plans and documents from the public.
Furthermore, these individuals, while acting as falsely unaware,
attempted to accuse the Company in `publically refuting' the presence
of metals in the tailings dam, accused the Company in concealing the
methodic by which the project documents were prepared', demanded
`expert information' (as if such information was not disclosed the
public), and, furthermore, claimed as if the information contained in
a scientific work that was published in 2010 (Sh. Khachatryan,
`Geological and chemical specifications of the Toukhmanuk Gold Mine')
contradicted the information provided by the Company, and further
claimed that the Company, its officers and specialists `deliberately
mislead the public, by concealing the content of the tailings to be
placed in the tailings dam and their potential effect on the health of
the residents of the community and the entire region'.
In fact, however, in November 27, 2012, the Company presented only the
construction project of its new tailings dam to be constructed for the
public hearings, including the environmental study for the
construction of the tailings dam. While, in fact, the Company
presented and implemented the public hearings for Toukhmanuk mining
plan back in April 21, 2006, in the community hall of Melikgyough
village, in presence of hundreds of attendees. For the purposes of
such hearings, the Toukhmanuk mining plan, including the open pit
plan, treatment plant plan, and the tailings dam construction plan
were presented and publically discussed, along with any and all
accompanying documents, analysis, and scientific reports, consisting
of hundreds of pages of documents. Community officials, residents,
public figures, intellectuals, National Assembly members, specialists,
NGO representatives, reporters, local clergy members, and others
simply interested in the Toukhmanuk project attended the hearings
(please see the pictures attached). The hearings took almost all day.
In the result, the detailed project documents, along with expert and
scientific substantiations, were filed to the Ministry of Environment,
along with the community's consent for the project to commence, and
for expert examination. In the result of the expert examination,
conducted in all detail and scrutiny, the Environmental Approval for
Toukhmanuk Mining Plan was issued. All the documents presented at the
hearings, then presented for the Approval, and even after the hearings
and such Approval, are publically available at the official bodies and
the Company, pursuant to Armenian Law on Freedom of Information.
Besides these open, transparent and public proceedings of 2008, the
Company prepared and filed the results of its massive geological
exploration of Toukhmanuk ore field in 2006, consisting of the result
of diamond drilling of 25,000 meters, surface and trench sampling, and
scientific report for this exploration. All these documents are also
publically available. In the result of the Company's scientific
research, the Toukhmanuk Pre Feasibility Study (including the
environmental impact study), the Toukhmanuk Metallurgical Reports
(four of them, for the years of 2008, 2009, and 2010), also the
Company's `Toukhmanuk Geological Exploration Report' for 2009, were
all prepared, and filed for approval of Toukhmanuk reserves at the
Ministry of Energy and Natural Resources. All these documents are
publically available, and the proceedings at the Ministry were all
open for public. In fact, the scientists (Sh. Khachaturyan), who,
according to the accusers, `revealed' the `concealed' information by
the Company, co - authored the Company's `Toukhmanuk Geologcial
Exploration Report', and the scientific work he published in 2010 is
just the brief version of the Company's 2006 Report.
One specific episode of attempts to falsely accuse the Company by
these individuals is typical: in their fabricated attempt to `reveal
the truth', one of this individuals, without notifying the Company or
inviting the Company to participate, and secretly from the Company,
initiated `sampling the tailings dam and the soils from the yards of
the villagers of Melikgyough', then falsely announced about`revealing
the concealed by the Company concentrations of some elements that
exceed the limits provided under the law', and placed the statements
in the internet, without analyzing, immediately.
For legal consideration, it is worth to mention, that Armenian law
(like the laws of other countries) does not provide `limits for
concentration of elements in the tailings'. Such statement is a mere
manipulation, and is aimed at misleading. The tailings are wastes,
they are neither eatable, nor drinkable, for the law to provide limits
of concentration of any elements in them. The waste is preserved in
the tailings dams, and isolated from the outside environment, just
because it is waste. Moreover, Armenian law considers the waste from
mining (tailings) as `non - dangerous' waste. This is a clear and
known fact.
The same individuals, by the way, repeatedly refused the Company's
offer to participate in the independent permanent environmental
monitoring, and even analyze the duplicates of the samples in
alternative laboratories, just to make sure that the results of the
monitoring are correct. The Company discovered only recently the
reasons for such refusal to participate, by the mentioned individuals.
Although the results of the lab assessments made by the representative
of NGO were not provided to the Company, the Company was able to
acquire them (see attached). According to the assessment made by one
of the labs of the Armenian National Academy of Science, the
concentration (mg/kg) of barium (BA) in the soil of the yards of
villagers exceeds the concentration of the same element in the
Company's tailings (waste) by up to 2,2 times, cobalt (Co) by 2,1
times , crome (Cr) by 2,3 times, copper (Co) by 1,8 times, nikel (Ni)
by 1,9 times, rubidium (Rb) by 1,4 times, tin (Sn) by 2,3 times,
stroncium (Sr) by 2,8 times, vanadium (V) by 2,3 times, zinc (Zn) by
15,2 times, circonium (Zr) by 2 times, iron (Fe) by 2 times, titan
(Ti) by 2 times.
According to this assessment, and the logic of concentration of
different elements, even if the Company tailings were not only
released (which is ruled out by the independent and permanent
environmental monitoring), but entirely replaced the soils (which is
impossible), the concentration of these elements would be much less
than those in the waste. It is also evident, that the Company waste is
much `cleaner', in consideration of the concentration of these
elements, than the soils of the villagers. If the concentration of
these elements in the soil was simply compared with the same
concentrations in the tailings, and given a simple analysis,
logically, the representatives should had thought of something else
than falsely accusing the Company in contaminating the soil.
Apparently, the villagers themselves told the representatives that
they are well aware, and were aware for a long time, of the
concentration of at least some of these elements in their soils even
before the Company activities began (during one of the meeting
organized by the representatives at the community, to which the
Company was not even invited), since back in soviet times large
amounts of different chemicals were widely used in the community
against rodents, and other chemicals as fertilizers, and even after
the soviet government's banning them, these chemicals were not removed
from the village, but buried in their soils instead, massively.
Fertilizers are still being used. Apparently, the representatives knew
about it, but choose to falsely accuse the Company instead, and even
disseminated a public statement claiming, as if, that the Company `is
refuting the results of the assessment' made by these
representatives. Instead, the Company is expecting that these
individual representatives themselves should refute their own
statements against the Company.
Moreover, understanding full well that their accusations against the
Company are entirely false and fabricated, the same representatives
organized different meetings at the Community, as if to discuss the
activity of the Company, but did not invite the Company or its
representatives to such meetings. During these meetings these
individual representatives are trying, through spreading a mere
obscurantism, provoke some individual residents to make false
statements against the Company purely for a smear propaganda purposes.
For example, during one of the meetings where the Company
representatives participated without being invited, an NGO
representative stated that the Company officers shall be `sentenced to
death by hanging' , not for harming the environment, but for just
mining the property, since mining is `evil', many other countries
banned mining at all and officially, as mining itself if harmful, but
encourage their companies mining in Armenia instead (such as Germany).
Company representatives witnessed during the same meeting, that a
specific person representing an NGO, would invite some individual
residents he personally knew out of the discussion room, coached them
what to say when back in the discussion room, while the other
individual representative would videotape in detail the resident's
yelling and simply cursing, and placing the video in the internet
later, as if a bright evidence of the communities `resistance'. This
behavior was not even being concealed, and no footages are placed in
the internet by these individual representatives, where the community
members not only disagree with their false accusation, but also oppose
them. As a result, artificially fabricated nature of the footages
placed in the internet by these individual representatives is
apparent.
This, indeed, is a disguised behavior. It is clear that some NGO
representatives apparently trying to put obstacles, and even stop the
activities of a company the record of which clearly provides that the
company not only proved its dedication to preventing any violations of
the environment, not only proved its dedication to social
responsibility, but also considered these issues as a top priority.
However, not only the false accusations against the Company don't
stop, but escalate instead, through dirty tactics.
Company's attempts to investigate such odd behavior resulted into sad
revelations that the Company is disclosing herein.
The Company was informed that some of these individual
representatives, apparently, applied to some international and local
sources asking for financing against environmental violations at
Toukhmanuk, often repeatedly and morbidly insisting. The Company was
also informed, that some international sources told these individual
representatives, that taking into account the transparent activities
of the Company, there are simply no evidence of any environmental
violations at Toukhmanuk, and there is an absolute absence of any
public awareness of such violations. Apparently, these individual
representatives understood the advice differently: public awareness
can be fabricated, and the evidence falsified. This is a simple soviet
approach, which does not lead to any results anymore.
The Company is still investigating the advice provided to these
individual representatives by the local sources to finance for
hindering or stopping the Company activities, however, the Company's
specific revelations currently available are also disturbing. It has
been for weeks, that one of these individual representatives, for
example, is posting in her personal facebook account (through opening
a special group) the materials posted in the internet and media a
while ago, for the purposes of smear propaganda initiated by a former
government official in the context of that official's corrupt demands
against the Company. This specific individual representative became so
exited, that even posted, and tried getting `likes' from facebook
audience, on the media reports about another company's activities with
the same name (Global Gold), in Kirgizia.
This behavior is extremely concerning, is harmful to the country, the
industry, the economy, facilitates the emigration - already a problem
for the country, is harmful for the reputation of NGOs, and shall be
stopped immediately. Representing group or individual interest by
individual representatives of NGOs, and their copying corrupt
officials' behavior cannot be allowed. Armenia deserves to have
environmental NGO truly dedicated at protection of the environment of
the country.
In light of these realities, the Company is hereby requesting these
individual representatives to disclose the international and local
sources their applied for their activities regarding Toukhmanuk mine,
and the purposes and conditions for such activities.
The Company will continue working transparently and openly, including
for the protection of the environment. As always, we are open for any
discussion that is aimed at serving interests of the communities of
the Company's operations.
Global Gold Mining, LLC Armenia Branch
- Social
News from Armenia and Diaspora - Noyan Tapan