Plenty of Evidence on Amulsar։ Harout Bronozian to Deputy Prime-Minister Avinyan

From Harout Bronozian to: Tigran Avinyan <>, Ararat Mirzoyan <>,,, <>,,,,

Dear Mr. Avinyan,

This is in regards to your recent statements below about the Amulsar Gold Mine Project in Armenia Ամուլսարի հարցում չունենք ապացույց, որպեսզի հայտարարենք բնապահպանական աղետի մասին. Տիգրան Ավինյան (In the case of Amulsar, we do not have evidence to declare about environmental disaster. Tigran Avinyan).

Lydian produced the Armenian version of the Amulsar project called SHMAG in 2016,  Have you or anyone you know read or evaluated this 839 page document for any discrepancies, errors or weaknesses?

Lydian’s latest technical document for the Amulsar project was produced on March 30, 2017 that supersedes previous Lydian documents (see below)?  Have you or anyone you know read or evaluated this document for any discrepancies, errors or weaknesses??,_2017.pdf

I would like to bring the following sections from this March 2017 document to your attention:

Section 18.4 page 276 says: “ARD (Acid Rock Drainage) treatment is needed starting in year 2021. The ARD treatment facility is located near the HLF and will be supplied by water from PD‐8. The maximum capacity of the ARD treatment is 40 m³/hr.”  As you can see Lydian considers that there will not be any need for ARD wastewater treatment for the first four years of operation.  Does Lydian or your independent consultants have an explanation for that? Wastewater treatment for any mine should start from day one, it is a known fact. So in what directions will that wastewater flow with a maximum capacity of 40 m³/hr, and what impacts will it have to the surroundings for four years, for a highly sensitive location.

As indicated in the topography here the mine is in the heart of water supplies in Armenia, in the middle of three main rivers, two reservoirs, one underground tunnel, that can also affect the Jermuk mineral water and even Lake Sevan. This figure from Lydian shows Groundwater Flow Pathlines during Operational Period indicating possible widespread contamination in groundwater and surface water due to acid mine drainage (AMD), page 6.9.23 of Please review this map showing the two tunnels bringing water to Lake Sevan from the proximity of the Amulsar project, located between the Spandarian and Kechut Reservoirs  With high levels of Acid Mine Drainage, what do you think can happen to the major water resources in Armenia including Jermuk and Lake Sevan?

Also please review page 397 of the same document.  It is clear that until March 2017 Lydian did not have a finalized geochemistry and ARD prediction, water treatment and water balance plan or even the money to do those evaluations.  Have you or anyone else contacted Lydian to get an updated version of the March 30, 2017 technical document and their much revised plan for ARD management? On page 397 it also says: “Unlike active treatment systems, a Passive Treatment System (PTS) must be designed to function under site‐specific conditions.” Active treatment systems are much more effective and flexible than passive treatment systems, since the quality and quantity of wastewater to be treated varies during the year.

“Failure to accurately predict acid rock drainage (ARD) leads to long-term impacts on ecosystems and human health, in addition to substantial financial consequences and reputational damage to operators.”  Lydian has failed in its accurate prediction of ARD in Amulsar.

“Acid Rock Drainage (ARD) is one of the most serious and potentially enduring environmental problems for the mining industry. Left unchecked, it can result in such long-term water quality impacts that it could well be this industry’s most harmful legacy. Effectively dealing with acid drainage is a formidable challenge as indicated by the high liability cost carried by many mining companies.”  Do you see Lydian in the list of INAP member companies on this web site?

If the above are not “evidences to declare about environmental disaster”, what evidences are you looking for Mr. Avinyan?

This video is indicative of the long distances covered by acid mine drainage,  Acid pollutes South Africa lakes

Are you aware of these shortcomings in this March 2017 document?  What environmental, technical or financial written guarantees do you have from Lydian, and what financial and legal penalties will Lydian get, when violations and failures occur? Can Lydian guarantee in writing a 98% performance for this highly sensitive location? Have you evaluated the environmental and economic gains and losses due to this project in detail?  Can you e-mail us a copy of that study, if it exists?

As you know, four of my former international independent mining consultants Drs. Andrea Gerson, Roger Smart, Ann Maest and André Sobolewski have evaluated the Lydian Amulsar project and documents for the past one year and distributed to your various ministries, Lydian, EBRD, and the public among others, 14 detailed reports. You can view our past technical evaluations here, and The latest report was prepared by Drs. Ann Maest and André Sobolewski, and was e-mailed on September 23, 2018 to Mr. Erik Grigoryan, Minister of Nature Protection and to Mr. Vardan Gevorgyan Deputy Minister of Energy Infrastructures and Natural Resources. This latest ten page report is titled “Report on our Trip to Amulsar Gold Project and Outstanding Project Risks”. This trip report focuses on their observations during their visit to Amulsar on June 21, 2018 and remaining concerns related to operation of the Amulsar Project and recommendations to the government of Armenia for improved environmental protection of water resources. Regarding risks the report says: “In our view, the greatest risks of this project are that acid drainage and contaminants leached from mined rock will enter surface waters and groundwater and contaminate sensitive and important water bodies in Armenia for centuries”. Are you aware about this report, and why it is not being made public? Have you or anyone else from your government studied and evaluated these 14 technical reports to be able to say that “In the case of Amulsar, we do not have evidence to declare about environmental disaster”?

This project is an extremely risky project due to its highly sensitive location; very low gold content that means the production of large open pits and enormous quantities of waste; total absence of any previous track record by Lydian; many weaknesses in the quality of the information that Lydian has provided to date; very weak and insufficient financial capabilities and performance guarantees by Lydian; and very low risk tolerance by the Armenian Government and People.  If you do not acknowledge the above mentioned most important risk factors Mr. Avinyan, maybe you can explain what do you consider as risk factors in this project? Maybe your and your Government’s risk tolerance levels are not low at all and all the above risk factors are acceptable by you and your Government. Disregarding these fundamental risk factors by the Armenian Government can lead to catastrophic consequences for the major water supplies in Armenia for hundreds of years. for which the Armenian Government can be held responsible and liable.

Lydian and its consultants misinformed and misrepresented the true nature of the Amulsar project and its true consequences and risks to the investors, banks, US, UK and Armenian Governments and the Armenian public, for which Lydian is responsible.  And you are all falling for it and accepting it without proper evaluation?  WHY? And the investors and the banks (IFC, EBRD) took Lydian’s arguments at face value without evaluating them properly. Being an Armenian-American who cares about his homeland, I took upon myself the responsibility to seriously and meticulously evaluate the Lydian English documents. The 14 highly technical reports of my former highly experienced international independent mining consultants brought to light that this project, if executed, would have resulted into environmental disasters that could affect the surrounding water resources for hundreds of years.  Taking into consideration the above risk factors, the consequences of this project can produce unpredictable and even irreversible social, economic, political and environmental outcomes.

In the light of all the above, has the contract between the Armenian Government and Lydian regarding the Amulsar project been re-evaluated by both sides, and what were the outcomes?  The Amulsar contract conditions can be found here  (Լիդիանի հետ պայմանագիրը)

This project by the wrong company in the wrong location with tremendous risks has no place in Armenia in my opinion. And inexperienced, unqualified, irresponsible and unprofessional people have nothing to do in decision making positions in Armenia, IF we want to make a difference, compared to the previous regime! Armenia is not for sale!  We have a country to build, not to destroy! 

Feel free to contact me for further information or assistance Mr. Avinyan.

Waiting for your response,
Kind regards,
Harout Bronozian
Chemical / Environmental Engineer, MS


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