The Ministry of Environment clarified in response to Azerbaijan's statement regarding the Yeraskh metal smelter.

"By Article 2 of the Convention on Environmental Impact Assessment in a Transboundary Context (from now on referred to as the Convention), "Each Party shall take the necessary legislative, administrative, and other measures to implement the provisions of this Convention, including those listed in Annex 1, significantly harmful for those types of planned activities with transboundary impact, the definition of such a procedure for environmental impact assessment, which will provide for the participation of the public, as well as the preparation of documents related to the ecological impact assessment provided for in Annex 2.

In this case, the planned activity is the processing of black metal scrap in the village of Yeraskh, Ararat region, RA, which is not included in the 1st Annex defining the types of activities of the Convention. The planned activities of "large furnace and marten smelting devices and non-ferrous metallurgy enterprises" included in the 1st Annex of the Convention are not included in any is not related to the intended activity in question since the process of casting black metal scrap will be carried out using an induction furnace, which works exclusively with electricity.

Moreover, the envisaged activity, taking into account Article 2, Part 5, and Annex 3 of the Convention, cannot be considered as having a significant transboundary harmful effect either, based on the following justifications:

The criteria set out in Annex 3 of the Convention are:

A/ volumes: Types of planned activities, the books of which are significant for a given type of activity,

Annual productivity of 108,000 tons is a small volume for ferrous metal scrap processing activity. The productivity of such processing plants generally starts from 1 million tons.

b/ district: Types of planned activities that are carried out in ecologically sensitive or essential areas or their immediate vicinity (for example, wetlands defined by the Ramsar Convention, national parks, natural reserves, zones of special scientific interest, archaeological, cultural, or historical monuments); also types of planned activities in regions where the characteristics of planned economic activities can have a significant impact on the population,

The closest specially protected area of nature in the territory of Nakhichevan is located about 5 km away from Yeraskh village in a straight line, and the planned activity cannot negatively impact the mentioned areas. The Ramsar Convention also defines no wetlands; the closest candidate is 12 km from the Emerald site in a straight line.

The impact of the planned activity on the existing archaeological, cultural, or historical monuments in this area is also excluded, considering that the nearest possible memorial is located at a distance of about 12 km in a straight line.

c/ consequences: Types of planned activities that have particularly complex and potentially harmful effects, including those that cause severe consequences for humans, valuable species, and organisms of flora and fauna, threaten the current or future use of the affected area and lead to the occurrence of an additional load that exceeds the level of environmental stability to external influences.

The area selection, the applied modern technology, and the planned environmental measures will minimize the negative impact on human health and the environment. Negative implications for atmospheric air are excluded. Gases emitted into the atmosphere contain carbon oxide and dioxide, hydrogen, oxygen, and nitrogen. A two-stage cleaning system will be installed on the exhaust gases, the efficiency of which will be 99%.

The installed systems will ensure a lower level of harmful substances in the gases emitted into the atmosphere than the limited permissible concentrations. In addition, to improve the dispersion conditions in the atmosphere, a 33-35m high pipe is planned to release gases into the atmosphere. The dust content in the exhaust gases from induction furnaces is several times less than from arc furnaces.

Impact on water resources is excluded. The water demand is planned to be met at the expense of groundwater, the level of which is very close to the surface of the area. Water for technical needs will be used only for cooling. The daily consumption of circulating water is planned to be 328.8 cubic meters. Water leakage from the production process is unplanned; the factory will work with a closed circulation system. 

The purified water can be discharged into the land canals in the area and used to irrigate the area.

The border river Araks is located 6 km away. A harmful effect is excluded, considering the production processes do not foresee any dangerous discharge into the water body. There is no impact on fauna and flora. There is no fauna and flora in this area; if encountering them, the law will implement appropriate conservation measures.

No negative impact on land resources can be considered either. The factory is planned to be built in an already disturbed area with half-destroyed buildings, dam remains, etc. There is no fertile layer of soil in the area subject to activity.

The established legal requirements will also carry out waste management. Ferrous metal scrap is a non-hazardous waste. The slag resulting from the smelting of black metal, which does not have a hazard class, is planned for road construction and other purposes, thus reducing waste accumulation in landfills.

Fresh water is used only to supplement the circulation system. A modern biological treatment plant with 95-98% efficiency is planned for domestic wastewater.