Amulsar Gold Project Threatens Water Supply "Our overall conclusion remains that the high risk of acid drainage and contaminant leaching, the poor geochemical evaluation, the inadequate water quality predictions and mitigation measures and Lydian’s inexperience combine to make this an environmentally high-risk project during mining and for a lengthy period after operations cease.
We are also concerned about public statements made by Lydian that the deposit is completely oxide, which erroneously implies that acid rock drainage (ARD) will not develop during or after mining. These statements do not reflect the reality of the situation on Amulsar Mountain if the mine is developed as planned. Accurate statements regarding the acid-forming components in this deposit from Lydian must be mandatory.
Lydian has responded to our reviews and have stated consistently that they remain confident in the “global best practice” mitigation measures developed for the Amulsar project. Public statements and reports by Lydian make it clear, however, that they have severely underestimated the potential adverse impacts of the mine, especially to water quality, which has been our primary focus and is commonly the most critical and long-term environmental concern for large-scale metal mines. Additionally, while Lydian’s consultants appear to have experience in certain aspects of mine operation and closure, we have seen no evidence that their principal consultant in the area of acid mine drainage, GRE, is experienced in the evaluation and understanding of ARD, geochemical characterization and interpretation of testing results, mitigation measures specifically aimed at ARD, and the effective treatment of ARD. We have extensive experience in these areas and provide a perspective that is independent of the mine proponent.
The project is located in an area that supplies clean water for drinking and agricultural uses across Armenia. There is a high risk, given the current mine and mitigation planning, that acid drainage and contaminant leaching will pollute groundwater; springs; the Arpa, Darb, and Vorotan rivers; and the Kechut Reservoir (Amulsar topography and surface waters are shown here). We hope that the Ministry of Nature Protection will review this final submission and re-evaluate Lydian’s proposed environmental plan in light of the likely long-term negative environmental impacts of this project.