Former Deputy Minister of Environment Anna Mazmanyan sent 2 letters to the Secretariat of the Berne Convention in 2021, calling the negative effects of the Amulsar project mentioned in the complaint of a group of non-governmental organizations unfounded.
Reminder: Andrey Ralev, on behalf of "Ecolur" Informational NGO, Armenian Forests NGO, Green Armenia NGO and CEE Bankwatch Network filed a network to Berne Convention Secretariat on Amulsar project.
The complaint mentions that Amulsar project is already located in “Jermuk Area” Emerald Candidate Area and may further have a significant impact on Emerald Network Candidate Areas such as Sevan National Park (AM0000002) and Gorhayk Area (AM0000002).
The complaint states that animal species, bird species, fish species and plant species (more than 50 species) listed in the annexes of the Berne Convention will be affected as a result of the implementation of the Amulsar project.
In her letter dated on 16 April 2021, Anna Mazmanyan noted, “Referring to the Complaint 2020/04: The Amulsar gold mine project and its impacts on Emerald Network sites, I would like to inform you that currently, relevant activities are being carried out for clarification and adjustment of all boundaries of potential sites, including "Jermuk", in order to cover the most important habitats and areas of plant and animal species, in accordance with the recommendations of the Convention. According to these recommendations plant and animal species and habitats of Emerald Network candidate sites are dispersed in eyery region as stated in the following categories: A: 15- 100% representation of the population of the species or the habitats; B: 2-15a, C:1-2, D: nonessential (less than 1%).”
Referring to the animal and plant species listed in the complaint, Anna Mazmanyan denied the availability of the following animal species in Amulsar project area: “All possible negative impacts presented in Complaint are unfounded and have not any scientific justification or evidence based predictions, since the existence of Mammal species listed in Complaint
(Persian leopard (Panthera pardus saxicolor], Grey wolf (Canis lupus); Bezoar goat (Capra oegogrus), Eurasian otter (Lutra lutro), Eurasian lynx (Lynx lynx), Brown bear (Ursus orctos), Marbled polecat (Vormela peregusna), Common bent-wing bat (Miniopterus schreibersii), Lesser mouse-eared bat (Myotis blythii), Geoffroy’s bat (Myotis emarginatus),' Mediterranean horseshoe bat (Phinolophus euryole),' Greater horseshoe bat (Phinolophus ferrumequinum)', Lesser horseshoe bat (Phinolophus hipposideros),‘ Mehely’s horseshoe bat (Rhinolophus mehelyi), IUCN Red List Vulnerable: mouflon (Ovis orientalis)), is not confirmed on the territory of the mine. Bird species presented in the Complaint [Common kingfisher (Alcedo atthis), Tawny pipit (Anthus camPestris), European nightjar (Coprimulgus europaeus), Corncrake (Crex crex), Syrian woodpecker (Dendrocopos syriacus), Ortolian bunting (Emberiza hortulano), Red- backed shrike (Lanius collurio), Lesser grey shrike (Lonius minor), Woodlark (Lullu la orboreo),' Bluethroat (Luscinia svecico), Red-billed chough (Pyrrhocorox pyrrhocorax), Barred warbler (Sylvia - 3 - T-PVS/Files(2021)50 nisorio),' Ruddy shelduck (Tadorno ferruginea), Lammergeier (Gypaetus barbotus), Egyptian vulture (Neophron percnopterus), Golden eagle (Aquila chrysaetos), Lesser spotted eagle (Clango pomarino), Booted eagle (Hieraaetus pennotus),’ Short-toed eagle (Circoetus gallicus)‘, European honey buzzard (Pernis aPivorus), Long- legged buzzard (Buteo rufinus), Montagu’s harrier (Circus pygargus), Peregrine falcon (Falco peregrinus), Lesser kestrel (Falco naumanni); Eagle owl (Bubo bubo), Greater short- toed lark (Colondrella brochydoctylo)) are not nesting in the indicated territory. Those species, which fly through the current territory, since they have large hunting ground s within their foraging range (such as Bearded vulture (Gypaetus barbatus), Golden eagle (Aquila chrysoetos), or Peregrine falcon (Falco peregrinus), have enough hunting area, as they already use other nearby territories. All the fish species (Aspius aspius, Lucio barbus comizo, Sabanejewio aurata], invertebrates (Euplogio quodripunctar io ) and plants species (Echium russicum) are not inhabiting the territory indicated in Complaint.
She notified the Berne Convention Secretariat that optimization of candidate sites of «Emerald Network» is currently being carried out and after the compilation of expert researches, the Ministry will officially submit the optimized list of candidate sites to the Secretariat of the Convention.
Anna Mazmanyan sent a letter with the same content to the secretariat of the Berne Convention on July 29, 2021, adding only that the optimization of the candidate areas of the Emerald network is being carried out, after which the optimized list of candidate locations will be presented to the secretariat of the convention.
Presenting the view point of the Ministry of Environment, Anna Mazmanyan did not refer to any document or scientific research, which would indicate on what basis and the presence of which species "Jermuk Area" was included in the list of Emerald candidate areas. It is not clear how the area of the Amulsar project was separated from "Jermuk Area" Emerald candidate area, on what grounds, if according to Anna Mazmanyan's letter, work is underway to adjust the Emerald candidate areas.
It should be noted that the species mentioned in the complaint of non-governmental organizations were presented based on the researches of WWF Armenia and Bulgaria-based "Balkan Wildlife Union" NGO, which were sent to the Ministry of Environment by letter.
On September 14-16, 2021, a session of the Bureau of the Bern Convention was held, where a decision was reached regarding the 2020/04 complaint filed by NGOs, which particularly says that according to the authorities, the mammal species presented in the complaint were not confirmed on the territory; the bird species do not nest on the territory, only fly across, and have large territories around; the fish, invertebrate and plant species indicated in the complaint also do not inhabit the territory.
The Bureau asked the authorities to provide the results of the conducted assessments showing that the project would not bring any negative impacts on species and habitats.
Once again, the Bureau expressed its concern at the expected large reduction in size of Emerald Network coverage in Armenia and again urged the authorities to clarify on when the revised list would likely be ready and submitted to the Secretariat.
October 27, 2022 at 11:15