On October 20, 2026, a civil society statement concerning Amulsar project was adopted and addressed to the Parties to the Bern Convention. It was endorsed by a number of civil society representatives. The statement was adopted during a discussion titled “Strengthening Civil Society Leadership and Biodiversity Governance Ahead of COP17 in Armenia,” organized by EcoLur Informational NGO with the support of the Armenian branch of the Heinrich Böll Foundation.
The statement says the following:
“On October 10, just days before the opening of the 17th meeting of the Conference of the Parties to the UN Convention on Biological Diversity (CBD COP17), the opening ceremony of the Amulsar gold mine took place, attended by the Prime Minister of the Republic of Armenia. We, representatives of civil society and non-governmental organizations, activists, and concerned citizens, view this step by the government as a demonstration of its prioritization of domestic interests over its international obligations, particularly those arising from the Convention on the Conservation of European Wildlife and Natural Habitats (the Bern Convention), which Armenia has signed and ratified.
In 2020, the Secretariat of the Bern Convention received a complaint from non-governmental organizations alleging that the project affects three Emerald Network candidate sites, three Important Bird Areas, one wetland of international importance under the Ramsar Convention, and 24 species listed by the International Union for Conservation of Nature (IUCN) as endangered or vulnerable.
The complaint identifies several major threats to biodiversity, including habitat destruction; pollution from dust and discharges; the destruction of animal and plant life; fragmentation of wildlife migration corridors around Mount Amulsar; and disturbances to wildlife, including poaching.
The examination of the complaint has lasted six years. During this period, both the Government of Armenia, represented by the Ministry of Environment, and the parties that submitted the complaint have provided annual reports.
Requirements of the Bern Convention and Responses from the Ministry of Environment
In 2026, the Standing Committee of the Bern Convention issued specific requirements to Armenia’s Ministry of Environment. These included:
· Conducting a new environmental impact assessment (EIA) for Amulsar project before mining operations begin.
· Establishing Jermuk National Park before CBD COP17 in Yerevan as a clear and decisive demonstration of Armenia’s commitment to biodiversity conservation.
· Completing consultations on the Emerald Network and submitting an updated database reflecting revised boundaries of Emerald Network sites, thereby enabling a Bern Convention biogeographical seminar to be organized. This step is essential for properly assessing the mining project’s impact on the relevant Emerald Network candidate sites.
In response to the requirement for a new EIA for Amulsar project, the Ministry of Environment stated that the existing positive EIA conclusion for the project and the related national permits remain in force.
Regarding the Emerald Network candidate sites, the Ministry stated that Armenia is reviewing candidate sites for inclusion in the Emerald Network and acknowledges the Bureau’s requirement to complete consultations and submit an updated database, including revised site boundaries.
Regarding the establishment of Jermuk National Park, the Ministry stated: ‘The process of establishing Jermuk National Park is in an active phase.’
Amulsar project also raises serious concerns regarding issues identified in previous expert assessments. An independent study conducted by ELARD and TRC in 2019 questioned the reliability of the project’s environmental assessment, particularly its evaluations of acid rock drainage, groundwater conditions, pollutant pathways, and potential impacts on the Arpa, Vorotan, and Darb rivers and the Kechut Reservoir.
The scale of the project makes these unresolved issues even more significant. According to the state environmental expertise conclusion, approximately 89,376,300 tonnes of ore are to be mined, containing 73,733 kilograms of gold (a declared gold grade of 0.78 grams per tonne) and 294,367 kilograms of silver (a declared silver grade of 9.29 grams per tonne). The document also specifies 106,490,056 cubic meters of overburden. However, earlier sources indicate that the total mass of overburden could reach 250–300 million tonnes. These figures need to be reconciled and verified to clarify the overall scale of the project and the scope of its environmental impacts.
The heap-leach pad, acid rock drainage, dust emissions, seismic hazards, and potential contamination of surface water and groundwater pose serious long-term risks. The project could also harm protected wildlife species and their habitats, disrupt ecological connectivity, and threaten Jermuk’s spa economy, which depends on the region’s natural environment and water resources.
The government’s approach of conducting monitoring after permits have been issued cannot replace a preventive environmental impact assessment before mining begins. Without a new EIA, scientifically justified boundaries for Emerald Network candidate sites, and effective protection of the Jermuk area, the project’s consequences remain inadequately assessed. These risks include environmental degradation; biodiversity loss; contamination of water and soil with cyanide and toxic metals; potential radioactive contamination; and damage to Jermuk’s spa infrastructure and health tourism sector.
In 2024, according to published reports, the Government of Armenia received a 12.5% stake in Lydian Armenia as a donation. As a shareholder, the government now has a direct financial interest in the project while also bearing responsibility for protecting the public interest and preventing environmental harm.
The requirements of the Bern Convention are directly relevant to the Green Agenda of CBD COP17. In this context, the Government of Armenia bears political responsibility for fulfilling the commitments established under relevant international policies, particularly the targets of the Kunming–Montreal Global Biodiversity Framework. Amulsar project threatens not only specific targets of this framework but also its underlying vision of living in harmony with nature.
The Amulsar issue has evolved from a local environmental conflict into one of the most significant challenges facing environmental and social governance in Armenia. It began as community opposition to a gold mining project and grew into sustained civil disobedience, legal and administrative appeals, international complaints, and scrutiny and oversight by international financial institutions and the Bern Convention.
We therefore call on the Standing Committee of the Bern Convention to:
1. Send a clear and unequivocal message to the Government of Armenia emphasizing that protecting and effectively managing the Emerald Network, establishing Jermuk National Park, and halting environmentally harmful activities, including mining, in protected areas are essential to fulfilling Armenia’s obligations under the Bern Convention and the Convention on Biological Diversity.
2. Engage with the relevant bodies of CBD COP17 to identify and pursue opportunities for cooperation aimed at protecting Armenia’s natural heritage and resolving outstanding issues related to Amulsar project.
3. Inform the Parties to the Bern Convention and the UN Convention on Biological Diversity of the Government of Armenia’s position regarding the Bern Convention’s requirements. The recommendations of the Bern Convention’s Standing Committee should serve as a benchmark for assessing Armenia’s biodiversity commitments and the actions planned under COP17.
4. Organize, as soon as possible, an independent expert on-the-spot appraisal (OSA) under the Bern Convention to assess the situation in the Amulsar and Jermuk areas.
The Bern Convention should not be left alone in its efforts to ensure that the Government of Armenia complies with its requirements. International organizations and institutions participating in COP17 must address a fundamental issue: the effective protection of the remaining natural areas on our planet. Armenia is one such area, where endangered species and vulnerable ecosystems urgently need protection.
We call on the Secretariat of the UN Convention on Biological Diversity, other international organizations, and partners to take practical steps within their respective mandates to prevent potentially severe and irreversible environmental damage, support the work of the Bern Convention Secretariat, and urge the Government of Armenia to effectively implement the recommendations of the Bern Convention Bureau. This must include conducting a new environmental impact assessment (EIA) and suspending all subsoil use permits until the new EIA process is completed.
Considering that the Government of Armenia has failed to comply with the requirements of the Bern Convention’s Standing Committee regarding Amulsar project;
Considering that the 1992 Earth Summit in Brazil recognized the need for coordination and cooperation among three key international environmental agreements within the UN system—the UN Framework Convention on Climate Change, the Convention on Biological Diversity, and the UN Convention to Combat Desertification—and that the Joint Liaison Group (JLG) was established to facilitate cooperation among them;
We call for a meeting of the Joint Liaison Group to be convened to discuss Amulsar project in the context of the Bern Convention’s requirements, adopt a relevant decision, submit it to the Government of Armenia, and publish it on the official websites of the respective conventions.
Considering that the Aarhus Convention provides an effective mechanism for protecting environmental rights and promoting public participation;
We call on the Secretariat of the Aarhus Convention to support the Bern Convention’s Standing Committee in its examination of the Amulsar case.
Signatories
· EcoLur Informational NGO
· Armenian Environmental Front civic initiative
· Healthy Hrazdan civic initiative
· Transparency International Anti-Corruption Center
· Center for Territorial Development and Research NGO
· Martuni Women’s Community Council NGO
· BLEJAN NGO
· Khazer Environmental and Cultural NGO
· Natural Economy Climate Civic Revolving Investment Fund
· Green Armenia NGO
· Armenian Women for Health and a Healthy Environment NGO
· Successful Woman NGO
· Civil Society Institute NGO
· ALT TV Company
· Forests of Armenia NGO
· Community Mobilization and Support Center NGO
· Dalma-Sona Foundation
· Healthy Environment NGO
· CEE Bankwatch Network
· Roza Julhakyan, expert
· Anush Nersisyan, expert
· Hayk Abrahamyan, expert
October 27, 2026 at 23:22