...The focus has been on the potential effects of the project on water resources, commonly the most critical and long-term environmental concern for large-scale
metal mines...The evaluation has found that the Amulsar Gold Project, as proposed, poses a high risk of long-term, adverse impacts to the environment. Our strong recommendation to the government of Armenia and its citizens is that the mine not be developed until the identified shortcomings are corrected...The highest priority concerns and consequences for development of the Amulsar Gold Project...are as follows: Contamination of downgradient groundwater, streams, springs, reservoir, tunnel from acid rock drainage and contaminant leaching that will last for centuries...Inadequate and incorrect geochemical evaluation of wastes and ore; underestimation of acid drainage and contaminant leaching potential of mined materials and negative impacts to the environment...The conclusion drawn by the Bronozian Consultants is that the high risk of acid drainage and contaminant leaching, the poor geochemical evaluation, the inadequate water quality predictions and mitigation measures, Lydian’s inexperience, and the insufficient financial guarantee combine to make this a high risk project during mining and for hundreds of years after operations cease...