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"LAKE SEVAN, GEGHARKOUNIK REGION, LITTORAL AREA REPRESENTATIVES COMPLAINT ADDRESSED TO EBRD AND IFC
13:16 December 11, 2014
EcoLur
"Lake Sevan, Gegharkounik Region, Littoral Area 18 representatives
have sent a Complaint to EBRD and IFC concerning Amulsar project. The
Complaint says, "We, the representatives of the active civil
society, live in the communities located on the shores of Lake Sevan,
Gegharkounik Region, read the opinion of the environmental expertise
of Nature Protection Ministry on Amulsar gold mining published on
28.11.2014.
The opinion says that the project area is a direct impact zone of Lake
Sevan (requirement 1: "RA Law "On Lake Seva", Article 8 says that the
zone of direct impact of Lake Sevan basin is an object of special
regulation, and when implementing urban development activities the
requirements of the governmental resolution N792-N shall be guided
with "On Approving Urban Development Procedure in Specially Regulated
Objects" and resolution "On Approving Master Plan of Lake Sevan
Drainage Basin", N1787 N dated on 11.12.2003").
The aforementioned shows that we, the residents of Lake Sevan littoral
communities, are also located in the zone of Amulsar project immediate
impact. If the requirements of the Nature Protection Ministry are
not fulfilled, while the water in Lake Sevan will be polluted with
the mining wastes through Arpa-Sevan canal, the residents of over 40
communities will be jeopardized with deprivation of the main source
of income - Lake Sevan. Gegharkounik region has very heavy climatic
conditions. We have scarce vegetation at over 2000 meters above sea
level. We came here and stayed to live here only for the sake of Lake
Sevan. Our incomes directly depend on the ecological state of the lake,
the pureness of its water, fish reserves, resort activities etc.
We are direct stakeholders in the matter of Amulsar project impact.
Nevertheless, our rights to the decision-making process on Amulsar
project, which are prescribed by the Aarhus Convention and RA Law "On
Environmental Impact Assessment and Expertise" were neglected. The
Nature Protection Ministry, which determines the list of the
communities in the project impact zone, didn't include our communities
in the project affected area. While "Geoteam" CJSC, which is entitled
to hold public hearings in the communities undergoing project impact in
line with RA Law "On Environmental Impact Assessment and Expertise",
didn't inform us in proper manner and didn't organize public hearings
in our communities.
We think that our statutory rights are violated both by the company
and the government.
The absence of relevant information and neglecting our rights to
decision-making process on Amulsar project didn't enable us, the
residents of Lake Sevan littoral area communities, taking part in
the discussion of Amulsar project in proper manner.
IFC Performance Standard 1, Assessment and Management of Environmental
and Social Risks and Impacts, Clause 8, has been violated, 'Where the
project involves specifically identified physical elements, aspects,
and facilities that are likely to generate impacts, environmental
and social risks and impacts will be identified in the context of
the project's area of influence. The area likely to be affected by:
(i) the project and the client's activities and facilities that are
directly owned, operated or managed (including by contractors) and
that are a component of the project.'
But our group was not identified when submitting the EIA of Amulsar
project, though the matter of impacting Lake Sevan was covered at
the public hearings many times.
The provisions of Clause 31 - Informed Consultation and Participation
were neglected, 'For projects with potentially significant adverse
impacts on Affected Communities, the client will conduct an Informed
Consultation and Participation (ICP) process that will build upon the
steps outlined above in Consultation and will result in the Affected
Communities' informed participation.'
We would like to advise that no informed consultation was held
either at community level or at the level of Gegharkounik regional
administration.
Performance Standard 4, Community Health, Safety, and Security,
has also been violated - ' The diminution or degradation of natural
resources, such as adverse impacts on the quality, quantity, and
availability of freshwater, may result in health-related risks and
impacts.'
Performance Standard 5, Land Acquisition and Involuntary Resettlement,
has also been violated: we would like to advise that nobody hold
discussions with the residents of the littoral communities located
in the immediate impact zone about involuntary resettlement, in case
Lake Sevan is exposed to the threat of pollution.
The same standards have been confirmed in the socio-environmental
policy of the EBRD. In addition, we would like to note that
the ban on the activities forbidden by the legislation of the
project-implementing country or the international conventions on
the protection of biodiversity and cultural heritage has also been
violated. The violation is as follows: Lake Sevan is inhabited
with endemic trout species, which are protected by RA Law 'On Lake
Sevan' and the activities will result in the change of the chemical
composition of the water conditioned with the industrial wastes.
The absence of proper information and neglecting of our rights to
decision-making participation on Amulsar project didn't enable us,
the residents of Lake Sevan littoral communities, to completely
participate in the discussion of the Amulsar project.
We think that, under such conditions, the opinion of the environmental
expertise must be reviewed and include 40 communities, located on the
shores of Lake Sevan, in the immediate project affected zone of Amulsar
project and once again hold public hearings in the communities and
only afterwards 'Environmental Expertise' SNCO must issue an opinion
to Amulsar project.
We think that the violation of our rights doesn't comply with the
EBRD and IFC standards and we would like to ask to obligate Lydian
International and its representative in Armenia, 'Geoteam' CJSC, to
withdraw its project and to include assessment on Lake Sevan impact
and its communities located in the immediate project affected zone.
On behalf of active civil society of Gegharkounik Region (list
attached) the complaint is lodged by Anahit Gevorgyan, Chairman of
'Women's Council of Martuni Communities".
http://ecolur.org/en/news/mining/vlake-sevan-gegharkounik-region-littoral-area-representatives-complaint-addressed-to-ebrd-and-ifc/6870/
13:16 December 11, 2014
EcoLur
"Lake Sevan, Gegharkounik Region, Littoral Area 18 representatives
have sent a Complaint to EBRD and IFC concerning Amulsar project. The
Complaint says, "We, the representatives of the active civil
society, live in the communities located on the shores of Lake Sevan,
Gegharkounik Region, read the opinion of the environmental expertise
of Nature Protection Ministry on Amulsar gold mining published on
28.11.2014.
The opinion says that the project area is a direct impact zone of Lake
Sevan (requirement 1: "RA Law "On Lake Seva", Article 8 says that the
zone of direct impact of Lake Sevan basin is an object of special
regulation, and when implementing urban development activities the
requirements of the governmental resolution N792-N shall be guided
with "On Approving Urban Development Procedure in Specially Regulated
Objects" and resolution "On Approving Master Plan of Lake Sevan
Drainage Basin", N1787 N dated on 11.12.2003").
The aforementioned shows that we, the residents of Lake Sevan littoral
communities, are also located in the zone of Amulsar project immediate
impact. If the requirements of the Nature Protection Ministry are
not fulfilled, while the water in Lake Sevan will be polluted with
the mining wastes through Arpa-Sevan canal, the residents of over 40
communities will be jeopardized with deprivation of the main source
of income - Lake Sevan. Gegharkounik region has very heavy climatic
conditions. We have scarce vegetation at over 2000 meters above sea
level. We came here and stayed to live here only for the sake of Lake
Sevan. Our incomes directly depend on the ecological state of the lake,
the pureness of its water, fish reserves, resort activities etc.
We are direct stakeholders in the matter of Amulsar project impact.
Nevertheless, our rights to the decision-making process on Amulsar
project, which are prescribed by the Aarhus Convention and RA Law "On
Environmental Impact Assessment and Expertise" were neglected. The
Nature Protection Ministry, which determines the list of the
communities in the project impact zone, didn't include our communities
in the project affected area. While "Geoteam" CJSC, which is entitled
to hold public hearings in the communities undergoing project impact in
line with RA Law "On Environmental Impact Assessment and Expertise",
didn't inform us in proper manner and didn't organize public hearings
in our communities.
We think that our statutory rights are violated both by the company
and the government.
The absence of relevant information and neglecting our rights to
decision-making process on Amulsar project didn't enable us, the
residents of Lake Sevan littoral area communities, taking part in
the discussion of Amulsar project in proper manner.
IFC Performance Standard 1, Assessment and Management of Environmental
and Social Risks and Impacts, Clause 8, has been violated, 'Where the
project involves specifically identified physical elements, aspects,
and facilities that are likely to generate impacts, environmental
and social risks and impacts will be identified in the context of
the project's area of influence. The area likely to be affected by:
(i) the project and the client's activities and facilities that are
directly owned, operated or managed (including by contractors) and
that are a component of the project.'
But our group was not identified when submitting the EIA of Amulsar
project, though the matter of impacting Lake Sevan was covered at
the public hearings many times.
The provisions of Clause 31 - Informed Consultation and Participation
were neglected, 'For projects with potentially significant adverse
impacts on Affected Communities, the client will conduct an Informed
Consultation and Participation (ICP) process that will build upon the
steps outlined above in Consultation and will result in the Affected
Communities' informed participation.'
We would like to advise that no informed consultation was held
either at community level or at the level of Gegharkounik regional
administration.
Performance Standard 4, Community Health, Safety, and Security,
has also been violated - ' The diminution or degradation of natural
resources, such as adverse impacts on the quality, quantity, and
availability of freshwater, may result in health-related risks and
impacts.'
Performance Standard 5, Land Acquisition and Involuntary Resettlement,
has also been violated: we would like to advise that nobody hold
discussions with the residents of the littoral communities located
in the immediate impact zone about involuntary resettlement, in case
Lake Sevan is exposed to the threat of pollution.
The same standards have been confirmed in the socio-environmental
policy of the EBRD. In addition, we would like to note that
the ban on the activities forbidden by the legislation of the
project-implementing country or the international conventions on
the protection of biodiversity and cultural heritage has also been
violated. The violation is as follows: Lake Sevan is inhabited
with endemic trout species, which are protected by RA Law 'On Lake
Sevan' and the activities will result in the change of the chemical
composition of the water conditioned with the industrial wastes.
The absence of proper information and neglecting of our rights to
decision-making participation on Amulsar project didn't enable us,
the residents of Lake Sevan littoral communities, to completely
participate in the discussion of the Amulsar project.
We think that, under such conditions, the opinion of the environmental
expertise must be reviewed and include 40 communities, located on the
shores of Lake Sevan, in the immediate project affected zone of Amulsar
project and once again hold public hearings in the communities and
only afterwards 'Environmental Expertise' SNCO must issue an opinion
to Amulsar project.
We think that the violation of our rights doesn't comply with the
EBRD and IFC standards and we would like to ask to obligate Lydian
International and its representative in Armenia, 'Geoteam' CJSC, to
withdraw its project and to include assessment on Lake Sevan impact
and its communities located in the immediate project affected zone.
On behalf of active civil society of Gegharkounik Region (list
attached) the complaint is lodged by Anahit Gevorgyan, Chairman of
'Women's Council of Martuni Communities".
http://ecolur.org/en/news/mining/vlake-sevan-gegharkounik-region-littoral-area-representatives-complaint-addressed-to-ebrd-and-ifc/6870/