Berne Secretariat Raised Status of Complaint on Amulsar

The Berne Convention Bureau reiterated its recommendation to halt any developments that can negatively affect the habitats and species protected under the Convention.

 The Bureau decided to elevate the complaint to stand-by, which has been filed by Andrey Ralev, Biodiversity Independent Expert, on behalf of "Ecolur" Informational NGO, Armenian Forests NGO, Green Armenia NGO and  CEE Bankwatch  Network.

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.

The Bureau reiterated its recommendation to halt any developments that can negatively affect the habitats and species protected under the Convention, whether it pertains to an Emerald Network site or not, and once again asked the authorities for a report specifically responding to the issue of the gold mine.

The Bureau recalled that the obligations under the Emerald Network exist for both candidate and adopted sites. It reminded that the authorities should follow Recommendation No. 208 (2019) of the Standing Committee on detecting, reporting, assessing and responding to changes in the ecological character of Emerald Network sites, and that they should respect the genuine interest of the Emerald Network. It further encouraged the authorities to involve all relevant stakeholders in the process, as the Berne Convention Secretariat letter addressed to RA Environment Ministry dated on 30 April 2021 says.

The Bureau had already expressed 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. It asked the authorities to provide an update on its Emerald Network structure to the Group of Experts on Protected Areas and Ecological Networks meeting in October 2021.

 In this regard, RA Deputy Environment Minister Irina Ghaplanyan’s letter no. 4/08.8/8058 dated on 21.07.2020 said that 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,” the letter of the Deputy Ministry said.

As it becomes clear from the letter of Berne Convention Secretariat, the Secretariat takes note of the report received from the Ministry of Environment on 16th April 2021. This report will be submitted for the Bureau’s attention at its next meeting on 15-16 September 2021. However should the Armenian authorities wish to send updates for that meeting, we would ask them to respect the deadline of 31st July 2021. The same deadline and information on reports apply to the complainant organisation for the submission of an updated report for the attention of the Bureau.

May 06, 2021 at 13:09