RA Environment Ministry has submitted its position in regard with the complaint filed by NGOs in terms of Amulsar gold-bearing quartzite mining project.
Reminder: In March 2020, Andrey Ralev, on behalf of "Ecolur" Informational NGO, Armenian Forests NGO, Green Armenia NGO and CEE Bankwatch Network, filed a complaint to the Bern Convention Secretariat. The complaint particularly said that the Armenian Government has violated Article 4, point 1 and 2, Article 5 and Article 6 of the Bern Convention by issuing permits to the Amulsar Gold Project and allowing significant impact on protected habitats and species from Resolution No. 4 (1996) and Resolution No. 6 (1998) of the Standing Committee. The project is situated within and has already impacted territories of Emerald Site "Djermuk" area AM0000009 and could have further significant impacts on other Emerald sites: "Sevan" National park AM0000002 and "Gorhayk" area AM0000002, all three adopted as candidate sites by the Standing Committee of the Bern Convention. Armenian Government disregarded procedures for evaluation of projects impacting Emerald sites by not doing proper assessment on protected species and habitats, and the EIA reports applied methodologies that violate the Bern Convention and are incompatible with the Emerald Network
In this regard, RA Deputy Environment Minister Irina Ghaplanyan’s letter no. 4/08.8/8058 dated on 21.07.2020 says:
The Ministry of Environment of the Republic of Armenia presents its compliments to the Secretariat of the Convention on the Conservation of European Wildlife and Natural Habitats and expresses its gratitude for the strong cooperation and contribution in bringing countries together to conserve the global nature.
Referring to the Complaint submitted to the Convention by Andrey Ralev, on behalf of "Ecolur" Informational NGO, Armenian Forests NGO, Green Armenia NGO and CEE Bankwatch Network I would like to bring your attention to the fact that this item remains high on our agenda.
Since 2008, the signature and ratification of the Bern Convention, Armenia has been working on setting-up of the Emerald Network according to the Bern Convention Resolutions No. 4 (1994) and No. 6 (1998). Accordingly, in 2017 the "Emerald Network" new list of candidate sites for Armenia was presented to the Secretariat of the Convention (uploaded to the site).
The submitted list of candidate sites was developed jointly by specialists and experts, and it was suggested both- to enlarge the borders of previously submitted sites and include new ones. As a result, the new list of candidate sites constituted 23 potential sites with more than 1 million ha of area, which comprises 34,7 % of the entire territory of the Republic of Armenia including "Djermuk" area, "Sevan" National park, "Gorhajk" area and other sites where major industrial and economic activities are underway.
The abovementioned list of candidate sites was not officially agreed neither with the Ministry of Environment (formerly Ministry of Nature Protection), nor circulated with other relevant state national authorities prior to submission to the Secretariat of the Bern Convention. We are currently investigating this procedural breach and will consecutively be taking respective measures to address it.
I would like to also note that a number of experts and specialists who participated in the project for the development of the candidate sites were contractually engaged as experts in the development of the EIA of the Lydian Armenia's Amulsar Gold Mine Project. This circumstance is also subject to further inquiry by the Ministry and possibly other relevant authorities.
In light of this and considering the fact that during different events organized within the framework of Convention the issue of revision of the Emerald Network candidate sites was discussed, the Ministry of Environment has initiated review and optimization of the previously submitted list.
In order to ensure evidence-based, rigorous and relevant data pertaining to candidate sites, additional and extensive field work is required. After the mentioned activities are implemented the Ministry of Environment will intern and officially communicate the optimized list of candidate sites of Emerald Network to the Secretariat of the Convention.
Allow me to once again to reiterate that we are committed to our obligations under the Bern Convention and we are ready to provide any additional information regarding this issue.
Irina Ghaplanyan – RA Deputy Environment Minister”
It should be mentioned that the position of RA Environment Ministry will be discussed at the second Bureau Meeting to be held on 15-16 September, 2020.
July 29, 2020 at 20:05