Letter to Nikol Pashinyan: New Factors on Amulsar Project Detected

Letter to Nikol Pashinyan: New Factors on Amulsar Project Detected


'EcoLur' Informational NGO, 'CEE Bankwatch Network' International Network and 'Balkani Wildlife Society', Bulgaria, have addressed a letter to Acting Prime Minister Nikol Pashinyan on the detection of new factors in Amulsar project, which says,

Dear Mr. Premier Minister,

In connection with the exacerbation of the socio-ecological situation caused by the Amulsar gold project, and the ambiguity of the conclusions of the expert working group on Amulsar, we submit to the government new facts reflected in the attached documents.

The first document is the Assessing the social impacts of the preparatory and development phases at Lydian International’s Amulsar mine in Armenia through surveys of neighbouring communities” sociological research, implemented by Dr. Anahit Mkrtchyan, Head of “Community Mutual Assistance” Social NGO.

The second document is the Report on New Circumstances Related to the Environmental and Social Impact Assessment (ESIA) of the Amulsar Gold Project in Armenia. implemented by the experts of Balkani Wildlife Society (Bulgaria).

Both investigations were prepared in October 2018 with the support of CEE Bankwatch Network, in the frame of the Make ICT Fair” project. The implementer of the project is the ICT Fair consortium (Swedwatch (project lead), CEE Bankwatch Network, University of Edinburgh, CATAPA, Le Monde Diplomatic, Towards Sustainability Association, People and Planet, Electronic Watch, SETEM Catalunya, Südwind and ICLEI.). The ICT Fair consortium organizations are acting together for reforming the Information and Communication Technology (ICT) manufacture and minerals supply chains within the project “Make ICT Fair”.

The main goal of investigations in Armenia is to support the implementation of Chapter 3 (Environment) of the Comprehensive and Enhanced Partnership Agreement between the European Union and the Republic of Armenia (CEPA). According to Article 45 of CEPA: "The Parties shall develop and strengthen their cooperation on environmental issues, thereby contributing to the long-term objective of sustainable development and greening the economy. It is expected that enhanced environmental protection will bring benefits to citizens and businesses in the European Union and in the Republic of Armenia, including through improved public health, preserved natural resources, and increased economic and environmental efficiency, as well as through the use of modern, cleaner technologies contributing to more sustainable production patterns".

Balkani main conclusions after the review of the Amulsar ESIA report are:

l  The Emerald network and Bern Convention are not given due consideration in the ESIA report and the ESIA report did not provide the responsible authorities in Armenia (Environmental Impact Analysis Center and Ministry of Nature Protection) with information that the project affects directly Emerald Network and adverse impacts could be expected;

l  In the ESIA report there is no assessment on the impacts of Amulsar gold project on the ecological characteristics of the Emerald sites.

l  The Amulsar ESIA applies methodologies not reflecting the provisions of the Bern Convention and incompatible with the Emerald Network of ASCIs.

l  The ESIA also fails to assess possible negative impacts on a number of protected species and habitats, as well as the possible impact of pollution of the Arpa river and possible threats to water ecosystems.

The Social report main conclusion is that the extremely positive and extremely negative opinions of the respondents are formed by insufficient awareness, complete denial of the negative consequences by a small group having a personal interest in the continuation of the mining operations and by influence of emotionally-intense field  on   opinion of  those who are not involved in mine activities.

In this context is important to add that the United Nations Special Rapporteur visited Yerevan on 16 November 2018. After his meetings with environmental groups protesting unsustainable naturalresources exploitation, he concluded that in past years there were restrictions for communities to access information, to participate meaningfully in public discussions and to provide consent when mining concessions were granted. In the case of Amulsar there is a lot of frustration around governance of natural resources, especially in communities who feel directly affected by impacts of activities, for example on water and local livelihoods, that is carried out in breach of national legislation. The protest of activists who blocked access to the mine demonstrates that the Government must consult with community members on the social and environmental impacts of the mine as well as on its benefits.

As a first step, the United Nations Special Rapporteur suggested that the government should carry out genuine consultations so that mining projects align with the Guiding Principles on Business and Human Rights and respect human rights and Sustainable Development Goals"- mainted in the report.

The reporst are in the attachments with the traslation in Armenian.

EcoLur Informational NGO

CEE Bankwatch Network

Balkani Wildlife Society


December 26, 2018 at 16:26