

EcoLur
“WORKERS' RIGHTS PROTECTION UNION” which has its representative office also in Germany, sent a letter to the German Development Bank KfW, in which it offers to increase transparency of creation and development of "Zangezur" biosphere complex project in order to avoid corruption risks. The letter reads as follows:
“Dear representatives of KfW Bank,
“Workers’ Rights Protection Union” NGO with its offices in Germany, is hopeful that the comprehension of problems related to the programs in Armenia with the financial support of KfW will result at the minimization of ecological and social risks.
First of all, we would like to refer to the biosphere complex "Zangezur" in Syunik. Our organization has been monitoring this issue since 2014 in the scope of the "Monitoring of social and environmental problems in the south of Armenia” project. We would like to remind that the Biosphere Complex "Zangezur" with an area of about 70 000 hectares was established in Syunik Marz of RA in 2013. It includes the National Park ''Shikahogh'', National Park ''Arevik'', state reserves “Plane Grove”, ''Zangezur '', ''Khustup”, "Bogakar” and “Black Lake”. Factually, the complex was built in agreement with the German KfW Development Bank, which promised to provide 8.25 million Euros for establishment and development of the complex.
The following problems were identified as a result of the monitoring:
- Management problem of “Zangezur” biosphere complex,
- The problem of supervision over the regime maintenance in “Zangezur” biosphere complex territory,
- The problem of transparency of the activities of the Government of RA and the German KfW Development bank with respect to the development of “Zangezur” biosphere complex,
- The problem of awareness and involvement of local communities in the creation and development process of “Zangezur” biosphere complex,
- The problem of impact assessment of mining activities and small hydroelectric power plants operating in the territory and in the buffer zone of "Zangezur" biosphere complex.
Therefore, a conflict of interests between mining companies, energy business, on the one hand, and the regime of special protected areas, on the other hand, are reflected in the following facts. In Syunik rights to mining are provided to 43 deposits, including 11 metals, and the rights to geological exploration to 29 deposits, including 29 metals. In Syunik 31 small hydroelectric power plants are constructed on the rivers, 12 small power stations are in the building process at present, Vorotan Cascade HPP is operating as well. At the same time licenses are issued to the companies whose activity is carried out both in the territory of "Zangezur" biosphere complex and in the buffer zone. In the course of issuing the permission documents, the process of environment protection expertise was carried out superficially, opinions of experts and the public on the existing risks were ignored and certain undeniable facts were ignored as well. For instance, the Ministry of Nature Protection claims that Tashtun gold-polymetallic deposit is out of “Arevik” National Park. However until now, the boundaries of the national park are not approved by the State Cadastre of Real Estate of RA. Consequently, the statement of the Ministry of Nature Protection concerning Tashtun deposit is meaningless. Moreover, there is a concern that the borders of “Arevik” National Park can be significantly narrowed precisely in order not to include Tashtun deposit, as well as other metal deposits, whose permissions are in the preparation process, into the territory of the National Park. It should be noted that in accordance with the initial assessment of independent experts of WWF, 40% of the project exploitation territory of Tashtun deposit is included within the borders of "Arevik" National park.
An attention should also be paid to the fact that the approval process of CBO borders is carried out in a strictly closed environment, as evidenced by the situation in communities that are deprived of opportunities to be informed in which boundaries they have the right to operate, and in which boundaries they are subjected to CBO regime.
The main problem is that the processes in "Zangezur" biosphere complex to a greater extent are subjected to political decisions, arising from the benefits of various companies or personal interests of decision-makers. A realistic assessment of the impact on the environment is not provided so far.
Taking into consideration the high value of "Zangezur" biosphere complex as one of the richest biodiversity sites of the world, we believe that all the funds provided for the creation and development of that special protected area should be spent purposefully excluding corruption risks, personal interests of people of high ranks affecting decision-making process. We offer to make transparent and accountable process of creation and development of "Zangezur" biosphere complex and carry out constant monitoring of the expenses directed to these activities, involving all stakeholders, namely government agencies, donors providing finance for creation of "Zangezur" biosphere complex, local administration, local population and civil society.”
July 08, 2015 at 16:28
