International Experts Respond to Artsvik Minasyan’s Invitation to a Meeting Around Amulsar Project’s Issues

We became aware from an email sent to the media and larger public by Harout Bronozian, chemical and environmental engineer, that he and internationally acclaimed mining experts that have been making extensive critiques on the possible exploitation of Amulsar gold mine, have responded to the invitation of Armenia’s Nature Protection Minister Artsvik Minasyan dated November 15, 2017 to participate in a joint meeting together with Lydian LLC some time in January. In their invitation letter Artsvik Minasyan mentioned that the aim of this meeting closed to media is to discuss the issue and management of acid drainage and its impact on underground waters and Vorotan-Arpa tunnel together with the specialists of Lydian.

What comes as a surprise is that before the above-mentioned invitation of the minister, media started circulating information about this meeting as if it was a jointly agreed fact already. Whereas on November 1st, 2017, Armenian Environmental Front inquired from the Ministry of Nature Protection clarification on the information disseminated by media, namely, who the participants of this meeting were and what kind of a legal authority this meeting would entail. From two inquiries back and forth, it became clear that the Ministry had leaked information as if the meeting involving international experts was finally confirmed, however the ministry was not able to give a list of participants, even the invitation sent to Harout Bronozian and international experts was issued at a later date. The responses also set out that the meeting was not going to be regulated by any legal norm, however with the agreement of the parties it would be held in a closed format (it is not clear which parties agreed on this if the ministry did not have a confirmed list of participants).

Moreover, even after our inquiries the Minister of Nature Protection and his advisor continued to mislead the media and the public presenting this meeting planned for January as a jointly confirmed event. Armenian Environmental Front evaluates this manner of work my the Ministry as media manipulation, since instead of the reality they only presented their or another party’s wishes.

Nonetheless, on December 24th, 2017, Harout Bronozian, chemical and environmental engineer, Dr. Andrea Gerson and Dr. Roger Smart from Blue Minerals Consultancy, Dr. Ann Maest from Buka Environmental and Dr. Andre Sobolevsky from Clear Coast Consulting officially responded to the Minister’s invitation, whereby they rejected the invitation justifying that they had up until that point not received credible answers from Lydian regarding the issues they had raised and that deep disagreements continued to persist, as well as some of the solutions to the significant environmental impact entailed political decisions and were of regulatory nature around which they were not in the position to negotiate.

The full text of the response of the international experts is presented below:

“December 24, 2017

For the attention of Mr. Artsvik Minasyan, Minister of Nature Protection of the Republic of Armenia.


We write this letter in response to an invitation by the Honorable Artsvik Minasyan, Minister of Nature Protection of the Republic of Armenia, to attend a meeting in Armenia regarding Lydian’s Amulsar Gold Project. Our group produced a series of critiques on the geochemical and water treatment aspects of this project. We subsequently received responses to our critiques from Lydian and their consultants and engaged in two rounds of arguments and counter- arguments. Despite these efforts, deep disagreements remain and our concerns that this project will have significant, long-term environmental impacts are undiminished.

Our initial review was thorough and reflected our expert evaluation of the project Environmental and Social Impact Assessment and associated documents. Subsequently, we responded to all objections from Lydian with demonstrable evidence, backed by citations from scientific publications and examples from existing mines. By contrast, we found many arguments rebutting our views to be opinions passed as facts. We heard of practices claimed by Lydian as Industry Standards that we, as authorities in the field, know not to be so. Despite these exchanges and lengthy responses, we find that Lydian has not accepted the case presented and has not offered credible responses to the issues raised. We are pessimistic about the prospects that they will ever do so.

We considered carefully the invitation by the Minister of Nature Protection to meet with ministry staff and Lydian representatives. We appreciated the benefits of explaining again the basis of our disagreement with their proposed ARD Management plan, including the scientific underpinnings of our understanding and concrete examples of existing practices that support our views. However, we are concerned that our attendance would be presented to the wider community as endorsement of the communiqué to be drafted at the end of the meeting, even if resolution was not achieved. Finally, we understand that some of the issues that require resolution are regulatory and political in nature, such as the development of permitted discharge limits or the requirement of reclamation bonds or other securities. As technical experts we are not the right people to negotiate these non-technical matters.

Taking these arguments into consideration, our consensus decision is to decline this invitation  as we are not confident this meeting will result in improved ARD planning and management. Instead, we will provide you within a few days with documents that present our final evaluation of this project as clearly, soundly, and succinctly as possible. We hope that the Armenian government and Lydian will seriously consider our concerns and recommendations and make the needed changes before mining proceeds.

Sincerely yours,

Harry Bronozian, Chemical / Environmental Engineer

Andrea Gerson, PhD, Blue Minerals Consultancy

Ann Maest, PhD, Buka Environmental Boulder

André Sobolewski, PhD, Clear Coast Consulting, Inc.

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