EcoLur has sent an enquiry to RA Nature Protection Ministry and RA Environmental and Mining Inspection Body to learn in which stage is the proposal of RA Environmental and Mining Inspection Body on annulling the state expert assessment opinion ԲՓ-35 issued to Lydian Armenia CJSC by RA Nature Protection Minister on 29.04.2016.
Reminder: RA Environmental and Mining Inspection Body substantiated its proposal with a newly emerged circumstance that red-listed Apollo butterfly has been detected in Amulsar, as well as red-listed Acantholimon Caryophyllaceum Boiss, where this butterfly lays eggs.
The letter 111/16.1/1001 of RA Environmental and Mining Inspection Body Head Arthur Grigoryan dated on 7 November 2018 addressed to EcoLur says, 'We would like to inform that according to the letter dispatched from RA Nature Protection Minister Erik Grigoryan, under RA Nature Protection Minister's decree N261-Ա on 3 September 2018 a working group was established, which examined the facts submitted by RA Environmental and Mining Inspection Body in the same places, where Parnassius apollo butterfly and, most probably, Acantholimon Caryophylaeceum Bois have been detected in the course of the inspection. Under the Minister's letter, this working group has provided a report and opinions to the Minister, which say:
1) The southern slope of Artavazdes Mountain in Amulsar gold quartzite mine area in Vayots Dzor Region (N39.72535 E045.71833, 2961m above sea level) is not a habitat or a living environment for Parnassius apollo.
2) In the area adjacent to the converter in Amulsar gold quartzite mine area in Vayots Dzor Region (N39.75158 E045.64145 և N39.75164 E045.64075 1994 m above sea level) no species of red-listed Acantholimon Caryophylaeceum Bois has been detected and this area is not a living environment or a habitat for Acantholimon Caryophylaeceum Bois. Under the initial assessment, only not red-listed commonly spread Acanthalimon glumaceum and Acanthalimon Takhtajanii species have been detected.
In view of the abovementioned, RA Nature Protection Minister informed that the facts submitted by RA Environmental and Mining Inspection Body in its letter N16/29/231 on 27 August 2018 in terms of Parnassius apollo and Acantholimon caryophylaeceum Bois are not new ecological factors emerged after issuing expert assessment in the context of RA law 'On Environmental Impact Assessment and Expertise'.
The Inspection Body is not aware of the criteria based on which RA Nature Protection Ministry selected the specialists having issued the opinions, as well as why the opinions of the other members of the working group established by RA Nature Protection Minister's decree are not submitted.
We would like to inform that Inspection Body Head asked Anush Nersesyan, a member of the working group established by RA Nature Protection Minister's decree N261-Ա, to provide the species of the plant gathered in the course of the mentioned visit to Eleonora Gabrielyan, Dr in Biological Sciences, Professor, a taxonomist of high-value plants at Institute of Botany of NAS RA and Izabella Arevshatyan, PhD in Biological Sciences, a taxonomist of high-value plants for their opinions. In reply to the letter, both specialists informed that this plant is Acantholimon caryophylaeceum Bois red-listed in Armenia (letters are attached).
What about the living environment or the habitat of Parnassius apollo, we advise that in accordance with Article 2 of the UN Convention of Biological Diversity a habitat means the place or type of site where an organism or population naturally occurs. According to Habitats Directive of the European Union which regulates the same matter, a habitat of a species means an environment defined by specific abiotic and biotic factors, in which the species lives at any stage of its biological cycle.
15:00 November 08, 2018